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thereof paid and may continue to pay for the Defendant Manufacturers' "preferred" drugs. All

unlawful conduct described above may have continued after Lisitza's tennination with

Omnicare.

COUNT XVIII Conspiracy to Submit False Claims in Violation of the Hawaii False Claims Act Haw. Rev. Stat. §661-21(C) (Against All Defendants)

  • 433.

    Plaintiffs reallege and incorporate by reference Paragraphs 1-261 set forth above.

  • 434.

    By effectuating the PAL letter solicitation-for-kickback scheme detailed herein,

Bristol Myers and Omnicare conspired to defraud the State of Hawaii by submitting false claims

and causing the submission of false claims for Monopril, Abilify, and other drugs.

435.

By effectuating a similar PAL letter solicitation-for-kickback scheme, Pfizer and

Omnicare conspired to defraud the State of Hawaii by submitting false claims and causing the

submission of false claims for Lipitor, Accupril, and other drugs.

436.

By effectuating a similar PAL letter solicitation-for-kickback scheme, Janssen and

Omnicare conspired to defraud the State of Hawaii by submitting false claims and causing the

submission of false claims for Risperdal and other drugs.

437.

By

effectuating

a

similar

PAL

letter

solicitation-for-kickback

scheme,

Ortho

McNeil and Omnicare conspired to defraud the State of Hawaii by submitting false claims and

causing the submission of false claims for Levaquin, UltramlUltracet, and other drugs.

438.

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.

99

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