Court also has jurisdiction under 31 U.S.C. §3732(a) over the Defendant Manufacturers because
their fraudulent acts, proscribed by 31 U.S.c. §3729, occurred in this District.
Venue is proper in this District under 31 U.S.C. §3732(a) and 28 U.S.C. §1391.
This suit is not based upon prior public disclosures of allegations or transactions
ill a criminal, civil, or administrative hearing, lawsuit or investigation, or in a government
Accounting Office or Auditor General's report, hearing, audit, or investigation, or from the news
media. To the extent that there has been a public disclosure unknown to Lisitza, Lisitza is an
original source under 31 U.S.C. §3730(e)(4), 740 ILCS 17S/4(e)(4), and other Plaintiff State
False Claims Acts. The facts and infonllation set forth herein are based upon Lisitza's personal
observation, investigation with counsel, and documents produced in this case. Lisitza has direct
and independent knowledge of the information on which the allegations are based and has
voluntarily provided the information to the government before filing a qui tam action.
On October 29, 2003, Lisitza provided to the Attorney General of the United
States, the United States Attorney for the Eastern District of Pennsylvania, the Attorney General
of Illinois, and other state Attorneys General a written disclosure statement of substantially all
known material evidence in accordance with the provisions of 31 U.S.C. §3730(b)(2), 740 ILCS
17S/4(b)(2), and other Plaintiff State False Claims Acts.
THE REGULATORY ENVIRONMENT
Numerous state and federal statutes and regulations serve to prevent fraud and
abuse in the Medicaid program. Defendant Manufacturers, in collusion with Omnicare, have
violated these statutes and regulations and have thereby defrauded the government and private
health insurance payors of tens of millions of dollars.