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contemplated by law, resulting in great financial loss to the federal and state governments.

606.

By virtue

of the

above-described

acts,

among

others,

Defendant Bristol

Myers

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 Tennessee, for Monopril,

Abilify, and other drugs.

607.

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 Tennessee, for Lipitor, Accupril, and

other drugs.

608.

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 Tennessee, for Risperdal

and other drugs.

609.

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 Tennessee, for Levaquin,

Ultram/Ultracet, and other drugs.

610.

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

Tennessee Medicaid, which were certified compliant with federal and state Medicaid law and

128

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