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

551.

The amounts of the false or fraudulent claims to the State ofNew Hampshire were

material.

552.

Plaintiff State of New Hampshire, 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.

COUNT XXX

Conspiracy to Submit False Claims in Violation of the New Hampshire Medicaid Fraud and False Claims Act N.H. Rev. Stat. §167:61-b (l)(c). (Against All Defendants)

553.

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

554.

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

Bristol Myers and Omnicare conspired to defraud the State of New Hampshire by submitting

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

555.

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

Omnicare conspired to defraud the State of New Hampshire by submitting false claims and

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

556.

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

Omnicare conspired to defraud the State of New Hampshire by submitting false claims and

causing the submission offalse claims for Risperdal and other drugs.

557.

By

effectuating

a

similar

PAL

lctter

solicitation-for-kickback

scheme,

Ortho

McNeil and Omnicare conspired to defraud the State of New Hampshire by submitting false

119

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