directly or indirectly, to officers, employees, or agents of the State of New Mexico, for Levaquin,
UltramlUltracet, and other drugs.
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 New Mexico, for Risperdal
and other drugs.
As a result of the claims for reimbursement defendants caused to be submitted to
New Mexico Medicaid, which were certified compliant with federal and state Medicaid law and
regulation as a condition of payment by co-conspirator pharmacies, New Mexico regularly made
payments to pharmacies for Defendant Manufacturers' illegally switched drugs.
The amounts of the false or fraudulent claims to the State of New Mexico were
Plaintiff State of New Mexico, 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
termination with Omnicare.
COUNT XXXII Conspiracy to Snbmit False Claims in Violation of the New Mexico Medicaid False Claims Act N.M. Stat. §27-14-4D (Against All Defendants)
Plaintiffs reallege and incorporate by reference Paragraphs 1-261 set forth above.
By effectuating the PAL letter solicitation-for-kickback scheme detailed herein,