claims and causing the submission of false claims for Levaquin, Ultram/Ultracet, and other
As a result of the claims for reimbursement defendants caused to be submitted to
New Hampshire Medicaid, which were certified compliant with federal and state Medicaid law
and regulation as a condition of payment by co-conspirator pharmacies, New Hampshire
regulaTly made payments to pharmacies for Defendant Manufacturers' illegally switched drugs.
The amounts of the false or fraudulent claims to the State of New Hampshire were
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 OnmicaTe.
COUNT XXXI New Mexico Medicaid False Claims Act
M. Stat. §27-14-1 et seq. (Against All Defendants)
Plaintiffs reallege and incorporate by reference PaTagraphs 1-261 set forth above.
This Count is brought by Plaintiff Lisitza individually and in the name ofthe State
of New Mexico under the qui tam provisions of the New Mexico Medicaid False Claims Act,
N.M. Stat. §27-14-1 et seq.
operated and continues to operate pharmacies in the State of New Mexico.