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indirectly, to officers, employees, or agents of the Commonwealth of Virginia, for Lipitor,

Accupril, and other drugs,

648,

By

virtue

of

the

above-described

acts,

among

others,

Defendal1t

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 Commonwealth of Virginia, for

Risperdal and other drugs,

649,

By viIiue

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 Commonwealth of Virginia, for

Levaquin, VltramlVltracet, and other drugs,

650,

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

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

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

payments to pharmacies for Defendant Manufacturers' illegally switched drugs,

651,

The amounts of the false or fraudulent claims to the Commonwealth of Virginia

were materiaL

652,

Plaintiff

State

of Virginia,

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,

135

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