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587.

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 State of New York, for Lipitor, Accupril, and

other drugs.

588.

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 New York, for Risperdal

and other drugs.

589.

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 New York, for Levaquin,

Ultram/Ultracet, and other drugs.

590.

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

New York Medicaid, which were certified compliant with federal and state Medicaid law and

regulation as a condition of payment by co-conspirator pharmacies, New York regularly made

payments to pharmacies for Defendant Manufacturers' illegally switched drugs.

591.

The amounts of the false or fraudulent claims to the State of New York were

material.

592.

Plaintiff State of New York, 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

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