The GLP-1 Short Form Complaint, Explained: The Blank Form + a Real Example

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The Form Every GLP-1 Case Is Filed On

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No Ozempic or other GLP-1 lawsuit has been settled, and no court or jury has found that these medications caused anyone's injury — the litigation is ongoing, with major expert-evidence rulings still ahead. Whether any individual has a claim depends on their own medical records and the law of their state.

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No Ozempic or other GLP-1 lawsuit has been settled, and no court or jury has found that these medications caused anyone's injury — the litigation is ongoing, with major expert-evidence rulings still ahead. Whether any individual has a claim depends on their own medical records and the law of their state. Do not stop, start, or change any prescribed medication because of anything on this page. Those decisions belong with your prescriber. Attorney Advertising.

The Short Form Complaint is the 11-page fill-in document that actually starts an individual Ozempic / GLP-1 lawsuit in MDL 3094. Since Case Management Order No. 27 (October 3, 2025), every new case in the MDL is filed this way: the form adopts the 264-page Amended Master Complaint by reference and adds the individual’s specifics — who they are, which medication, which injury, which legal counts. This page walks through the form field by field, using the blank court version and a real, completed example from the public docket.

What the short form complaint is — and the rules that give it force

A short form complaint (“SFC”) is not a summary or an intake form — it is the operative pleading. Under CMO 27, “the Master Complaint together with the Short Form Complaint shall be deemed the Plaintiff’s operative Complaint” (¶ 2), and any claims pleaded in an SFC “supersede and replace” whatever complaint the case had before (¶ 10). Every case filed in the MDL after October 3, 2025 must use it; cases already pending were given 60 days to convert (90 days for firms with more than 500 cases) (¶ 9).

Four mechanics matter most:

• Where it’s filed. Never on the master docket — each SFC is filed on the plaintiff’s own member-case docket in the Eastern District of Pennsylvania, and every member case must have a complaint on file (¶ 12).
• The deadline rule. For statutes of limitations and repose, a plaintiff’s case is deemed initiated on the date of their original complaint or their SFC, whichever was filed first (¶ 11). Converting an older case to the short form does not reset or endanger the original filing date — and for a first-time filer, the SFC date is the date that matters. Our state pages cover how each state’s deadline runs.
• No answer is coming. Every SFC in the MDL is automatically “deemed answered and denied,” with all defenses preserved (¶ 13). The defendants file nothing in response, and motions to dismiss individual member cases require a further court order (¶ 14).
• Direct filing. Under the Direct Filing Order (CMO 14, Doc. 190, July 2024), cases from anywhere in the country are filed straight into the MDL court, with streamlined service on the defendants — skipping the months a case would historically have spent waiting for a transfer order. The trade: the form asks where the case would have been filed (its ¶ 11), and the defendants preserve jurisdiction and venue challenges for that home court (CMO 27 ¶ 8).

What the Direct Filing Order actually does

The short form complaint only works because of a second order sitting underneath it. Case Management Order No. 14 — the Direct Filing Order, Doc. 190, July 2024 — is what lets a case from anywhere in the country be filed straight into the MDL in Philadelphia instead of waiting months for a JPML transfer. It also sets the rules that shape what every filed case looks like.

One plaintiff per complaint. A directly filed case may not name more than one plaintiff. The only additions permitted are the claims attached to that plaintiff’s own — a spouse or family member bringing loss of consortium, or the representative and estate distributees in a wrongful-death or survival claim. There is no mass joinder in this MDL; every case on the docket is one person’s.

Only two Novo entities can be named. For directly filed cases alleging Ozempic, Rybelsus, Wegovy, Victoza and the other drugs the JPML has added, the order permits only Novo Nordisk Inc. and Novo Nordisk A/S as Novo defendants. That is why the Novo captions across these dockets read the same way. The parties told the court they would address claims against other Novo entities separately, while preserving the right to obtain discovery from all of them.

Service is streamlined, and it runs on a clock. Eli Lilly, Novo Nordisk Inc. and Novo Nordisk A/S waived formal service under Rule 4 and accept service by email at addresses the order designates, one complaint and summons per email. Waiving service is not waiving defenses. A plaintiff whose case is not yet docketed in the MDL has 90 days from the date it is docketed to serve, and the date of the first email attempt counts as the date of service. Defendants must give 30 days’ written notice before moving to dismiss over a technical defect in that process.

The defense can object to a case being in the MDL at all. Defendants have 30 days to file a Notice of Objection to Inclusion of a directly filed case, which starts a 14-day meet-and-confer. If it is not resolved, the plaintiff may refile in an appropriate district within 30 days — and the defendants agreed not to raise any statute of limitations that lapsed between the original filing and the refiling. Limitations defenses that already existed before the first filing are expressly retained.

What direct filing does not decide. Filing into the MDL is not a ruling that Philadelphia is the proper venue, and it does not settle which state’s law governs — the order reserves choice of law for later. It also preserves every party’s Lexecon rights: the MDL court handles pretrial proceedings only, and where a case is ultimately tried stays open, decided later under 28 U.S.C. § 1404(a) after the parties confer. That is why these pages describe a home district as a case’s designated venue rather than a guaranteed destination.

The form, field by field

Identification of parties (¶¶ 1–5)

The form opens with who is suing: the injured person’s full name (¶ 1), and — only where they apply — the representative bringing a wrongful-death claim for a deceased user (¶ 2), an estate’s survival claim (¶ 3), or a spouse’s or family member’s loss-of-consortium claim (¶ 4). Paragraph 5 is the first checkbox set: which defendants are being sued — Novo Nordisk Inc., Novo Nordisk A/S, Eli Lilly and Company, Lilly USA, LLC, or others. The choice tracks the medication: the Novo entities made Ozempic, Wegovy, Rybelsus, Victoza, and Saxenda; the Lilly entities made Trulicity, Mounjaro, and Zepbound. A plaintiff who used products from both manufacturers — like the hosted example — checks all four.

Jurisdiction and venue (¶¶ 6–13)

Four residence questions do real work: where the plaintiff lives now (¶ 6), the state where the medication was prescribed (¶ 7), the state of residence during use (¶ 8), and residence at diagnosis (¶ 9). These anchor which state’s law applies — the master complaint pleads every count “pursuant to all laws that may apply according to choice of law principles, including the law of each Plaintiff’s resident State,” so these boxes are where a case’s governing law starts to crystallize. Paragraph 10 states the basis for federal jurisdiction (nearly always diversity of citizenship); ¶ 11 names the district court where the case would otherwise have been filed — the likely trial court if the case is ever remanded — and ¶ 12 states why venue is proper there.

Product use (¶¶ 14–15)

Nine product checkboxes — Ozempic, Wegovy, Rybelsus, Victoza, Saxenda, Trulicity, Mounjaro, Zepbound, and other — plus the approximate date range of use for each, by month and year. Date ranges matter twice over: they frame causation (use must precede injury) and they interact with each state’s filing deadline.

Injuries and damages (¶¶ 16–18)

Paragraph 16 is the form’s medical heart — twelve injury checkboxes, reproduced here as the form lists them:

• Gastroparesis — delayed stomach emptying; the litigation’s signature alleged injury
• Other gastro-intestinal injuries — a specify-in-writing line
• Ileus — the intestine stops moving contents through
• Ischemic bowel / ischemic colitis — restricted blood flow to the intestine
• Intestinal obstruction — a physical blockage of the bowel
• Necrotizing pancreatitis — severe pancreatitis with tissue death
• Gallbladder injury — with a specify line (the example lists a cholecystectomy — gallbladder removal)
• Micronutrient deficiency — e.g., thiamine or B12 deficiency from persistent vomiting
• Wernicke’s encephalopathy — a neurological emergency caused by severe thiamine deficiency
• Aspiration — stomach contents entering the lungs, an alleged anesthesia-related risk
• Death
• Additional / other — specify line

Checking a box is an allegation, not a diagnosis — each checked injury has to be backed by medical records as the case proceeds; for gastroparesis that ultimately means an objective gastric emptying study. Paragraph 17 asks when the injuries occurred (month and year), and ¶ 18 catalogs the damages categories: injury to self or to a person represented, economic loss, wrongful death, survivorship, loss of services, and loss of consortium. Note what is not on the injury list: NAION vision loss is litigated in the separate MDL 3163, not through this form.

Causes of action (¶ 19) — the sixteen-count menu

Paragraph 19 lists all sixteen counts of the Amended Master Complaint as checkboxes. Checking one adopts that count’s allegations by reference — each links here to our dissection of what it actually says: I · Failure to Warn – Negligence, II · Failure to Warn – Strict Liability, III · Express Warranty, IV · Implied Warranty, V · Fraudulent Concealment, VI · Fraudulent Misrepresentation, VII · Negligent Misrepresentation, VIII · Strict Liability Misrepresentation, IX · Innocent Misrepresentation, X · Unfair Trade Practices, XI · Negligence, XII · Negligent Undertaking, XIII · State Product Liability Acts, XIV · Wrongful Death, XV · Loss of Consortium, and XVI · Survival Action. There is also an “Other(s)” line: additional claims can be pleaded on separate pages with full supporting facts — which is how case-specific fraud allegations enter individual cases.

The two traps: ¶¶ 20 and 21

Two of the sixteen counts cannot simply be checked — the Court built specificity requirements directly into the form, each carrying the same warning, quoted in the form itself from the motion-to-dismiss opinion: failure to plead with the requisite specificity “will result in the short form complaint being stricken with only one opportunity to amend” (Doc. 465 at 74 n.33 & 76 n.35).

• ¶ 20 — consumer-protection claims (Count X). The plaintiff must identify the exact statute and subsections they sue under, plus the factual allegations supporting each. The statutes pleaded state-by-state are inventoried in our master-complaint table.
• ¶ 21 — state product-liability-act claims (Count XIII). Three sub-questions: the PLA and subsections, which legal theories the PLA claim subsumes, and the supporting facts. In the eleven PLA states this paragraph effectively restructures the whole case, because the act can absorb several common-law counts.

Paragraph 22 closes the questions: whether any statute-required pre-suit notice was given, with the notice attached. Then the relief prayer and jury demand — standardized — and counsel’s signature block.

A real one, walked through

The hosted example is the Short Form Complaint of an Indiana plaintiff, filed January 9, 2026 as Doc. 1 in member case No. 2:26-cv-00136 — chosen because it exercises nearly every feature of the form. The plaintiff, a Terre Haute resident, used Ozempic (two periods across 2020–2023) and then Trulicity (late 2023), so the form names all four defendants — both Novo entities and both Lilly entities — and gives a date range per product (¶¶ 14–15). The injury checked is gallbladder injury, specified as a cholecystectomy after an emergency admission, with the date and sequence pleaded in ¶ 17. The Southern District of Indiana is named as the home court under ¶ 11.

The back half is where the form’s hardest requirements show up. For Count XIII, its ¶ 21 does exactly what the Court required: it cites the Indiana Product Liability Act by section (Ind. Code § 34-20-1-1 et seq., with five specific provisions), lists which of the master complaint’s counts are subsumed into the PLA claim under Indiana law, and pleads supporting facts. It then adopts the master complaint’s counts by paragraph range — the same ranges our count-by-count dissection uses. And because the plaintiff asserts the fraud counts (V and VI), the filing attaches a separate Exhibit A “fraud supplement” pleading the specific alleged omissions and misrepresentations — concealment of severe GI risks, the adequacy of gastric-emptying testing, anti-emetic use in trials, weight-regain and muscle-loss claims, and named advertising campaigns — with the particularity that Rule 9(b) demands. That supplement is a direct, practical consequence of the August 2025 ruling: the fraud counts survived only in repleaded form, and individual plaintiffs asserting them carry the specificity burden case by case.

One caution in reading it: this is one plaintiff’s pleading, reproduced from the public record as filed. Its allegations are unproven, its claim selections reflect Indiana law and that plaintiff’s facts, and nothing about it predicts any other case’s filing — a different state and different injury produce a differently completed form.

What a filed short form complaint does not mean

Filing an SFC places a case in the MDL — nothing more. It is not a finding, a settlement registration, or a payout queue: no GLP-1 case has reached a verdict and none has settled, and the litigation’s decisive fight — whether plaintiffs’ general-causation experts are admissible under Rule 702 — is scheduled for hearings in September 2026. A filed case can still be dismissed, withdrawn, or lost. And the form is built for lawyers: it is signed by counsel with bar number and firm, its checkbox choices carry state-law consequences (¶¶ 20–21 especially), and an error in them costs a stricken pleading with one chance to fix it.

Common questions

No Ozempic or other GLP-1 lawsuit has been settled, and no court or jury has found that these medications caused anyone’s injury — the litigation is ongoing, with major expert-evidence rulings still ahead. Whether any individual has a claim depends on their own medical records and the law of their state.

Do not stop, start, or change any prescribed medication because of anything on this page. Those decisions belong with your prescriber.

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This page is attorney advertising and is for informational purposes only; it is not legal or medical advice. Prior results do not guarantee a similar outcome. Contacting the firm does not create an attorney-client relationship.