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

other drugs.

528.

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 Nevada, for Levaquin,

Ultram/Ultracet, and other drugs.

529.

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 Nevada, for Risperdal and

other drugs.

530.

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

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

regulation as a condition of payment by co-conspirator phannacies, Nevada regularly made

payments to pharmacies for Defendant Manufacturers' illegally switched drugs.

531.

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

material.

532.

Plaintiff State of Nevada, 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.

115

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