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directly or indirectly, to officers, employees, or agents of the Commonwealth of Massachusetts,

for Monopril, Abilify, and other drugs.

487.

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 Commonwealth of Massachusetts, for Lipitor,

Accupril, and other drugs.

488.

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 Commonwealth of Massachusetts,

for Risperdal and other drugs.

489.

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 Commonwealth of Massachusetts,

for Levaquin, UltramlUltracet, and other drugs.

490.

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

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

and regulation as a condition of payment by co-conspirator pharmacies, Massachusetts regularly

made payments to pharmacies for Defendant Manufacturers' illegally switched drugs.

491.

The

amounts

of

the

false

or

fraudulent

claims

to

the

Commonwealth

of

Massachusetts were material.

108

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