X hits on this document

465 views

0 shares

0 downloads

0 comments

10 / 147

20.

Defendant

Manufacturers'

unlawful

activities

were

not

limited

solely

to

Omnicare. The specific circumstances alleged herein evidence a pattern of conduct designed to

maximize profits at every opportunity at government and private insurers' expense. Defendant

Manufacturers effected the kickbacks-for-switches scheme with other pharmacies wherever it

was possible and profitable, costing the government and private insurance companies tens of

millions of dollars.

  • II.

    PARTIES

    • 21.

      Plaintiff and Relator Lisitza is a citizen and resident of the State of Illinois. For

more than five years, Lisitza worked for Omnicare as a pharmacist and a pharmacy supervisor.

Lisitza brings this action on his own behalf, on behalf of the federal government pursuant to 31

U.S.C. §3730(b)(1), on behalf of the government of the State of Illinois pursuant to 740 ILCS

175/4(b)(1), and 740 ILCS 92/1 et seq., and on behalf of the states of California, Delaware,

Florida, Georgia, Hawaii, Indiana, Louisiana, Michigan, Nevada, New Hampshire, New Mexico,

New York, Tennessee, Texas, the Commonwealths of Massachusetts and Virginia, and the

District

of

Columbia

pursuant

to

their

respective

False

Claims

Acts.

The

listed

States,

Commonwealths, and the District of Columbia will be referred to throughout as "Plaintiff

States." Plaintiff States, the federal government, and Lisitza individually will be collectively

referred to as "Plaintiffs."

22.

Defendant Bristol Myers Squibb, Inc. ("Bristol Myers") is a Delaware corporation

with its headquarters in New York, NY, and a principal research facility in New Brunswick, NJ,

within 100 miles of Philadelphia, PA. Bristol Myers sells its pharmaceutical products, including

Monopril and Abilify, in this District and nationwide. Monopril is the brand name of fosinopril

sodium, a member of a class of drugs known as angiotensin-converting enzyme inhibitors ("ACE

6

Document info
Document views465
Page views465
Page last viewedFri Dec 02 22:50:23 UTC 2016
Pages147
Paragraphs7751
Words41508

Comments