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

payments to pharmacies for Defendant Manufacturers' illegally switched drugs.

611.

The amounts of the false or fraudulent claims to the State of Tennessee were

material.

612.

Plaintiff State of Tennessee, 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 Omnicare.

COUNT XXXVI

Conspiracy to Submit False Claims in Violation of the Tennessee Medicaid False Claims Act Tenn. Stat. §71-S-182(C) (Against All Defendants)

6l3.

Plaintiffs reallege and incorporate by reference Paragraphs 1-261 set forth above.

614.

By effectuating the PAL letter solicitation-for-kickback scheme detailed herein,

Bristol Myers and Omnicare conspired to defraud the State of Tennessee by submitting false

claims and causing the submission offalse claims for Monopril, Abilify, and other drugs.

615.

By effectuating a similar PAL letter solicitation-for-kickback scheme, Pfizer and

Omnicare conspired to defraud the State of Tennessee by submitting false claims and causing the

submission of false claims for Lipitor, Accupril and other drugs.

616.

By effectuating a similar PAL letter solicitation-for-kickback scheme, Janssen and

Omnicare conspired to defraud the State of Tennessee by submitting false claims and causing the

submission of false claims for Risperdal and other drugs.

617.

By

effectuating

a

similar

PAL

letter

solicitation-for-kickback

scheme,

Ortho

129

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