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427.

By

virtue

of

the

above-described

acts,

among

others,

Defendant

Janssen

knowingly caused to be presented false or fraudulent claims for payment or approval, and

possibly continues to cause to be submitted false or fraudulent claims for payment or approval,

directly or indirectly, to officers, employees, or agents of the State of Hawaii, for Risperdal and

other drugs.

428.

By virtue of the above-described acts, among others, Defendant Pfizer knowingly

caused to be presented false or fraudulent claims for payment or approval, and possibly

continues to cause to be submitted false or fraudulent claims for payment or approval, directly or

indirectly, to officers, employees, or agents of the State of Hawaii, for Lipitor, Accupril, and

other drugs.

429.

By virtue of the above described acts, among others, Defendant Ortho McNeil

knowingly caused to be presented false or fraudulent claims for payment or approval, and

possibly continues to cause to be submitted false or fraudulent claims for payment or approval,

directly or indirectly, to officers, employees, or agents of the State of Hawaii, for Levaquin,

Ultram/Ultracet, and other drugs.

430.

As a result of the claims for reimbursement defendants caused to be submitted to

Hawaii Medicaid, which were certified compliant with federal and state Medicaid law and

regulation as a condition of payment by co-conspirator pharmacies, Hawaii regularly made

payments to pharmacies for Defendant Manufacturers' illegally switched drugs.

431.

The amounts of the false or fraudulent claims to the State of Hawaii were

material.

432.

Plaintiff State of Hawaii, being unaware of the falsity of the claims and/or

statements caused to be made by the Defendant Manufacturers, and in reliance on the accuracy

98

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