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474.

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

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

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

475.

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

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

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

476.

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

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

submission of false claims for Risperdal and other drugs.

477.

By

effectuating

a

similar

PAL

letter

solicitation-for-kickback

scheme,

Ortho

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

causing the submission of false claims for Levaquin, Ultram/Ultracet, and other drugs.

478.

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

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

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

payments to pharmacies for Defendant Manufacturers' illegally switched drugs.

479.

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

material.

480.

Plaintiff State of Louisiana, 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

thereof paid and may continue to pay for the Defendant Manufacturers' improperly switched

prescriptions.

All

unlawful

conduct

described

above

may

have

continued

after

Lisitza's

termination with Omnicare.

106

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