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660.

Plaintiff

State

of Virginia,

being

unaware

of the

falsity

of the

claims

and/or

statements caused to be made by the Defendant Manufactmers, and in reliance on the accmacy

thereof paid and may continue to pay for the Defendant Manufactmers' improperly switched

prescriptions.

All

unlawful

conduct

described

above

may

have

continued

after

Lisitza's

termination with Omnicare.

COUNT XLI Illinois Insurance Claims Fraud Prevention Act 740 ILCS 92/1 et seq. (Against All Defendants)

661.

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

662.

Relator is an interested person with direct, personal knowledge of the allegations

of this complaint, who has brought this action pmsuant to 740 ILCS 92/1 et seq. on behalf of

himself and the State of Illinois.

663.

By

committing

the

acts

alleged

above,

Defendant

Manufactmers

violated

740

ILCS 92/1 et seq. by repeatedly, willfully and intentionally conspiring to submit and causing

false claims for reimbmsement to be submitted to insurers for prescription drugs that were

provided to patients as the result of kickbacks, switching drugs without informed physician

authorization, and other misrepresentations and omissions from 1998 to date.

664.

By concealing and/or by failing to disclose the fact that the claims to be submitted

to insmers were for prescription drugs provided to patients as a result of kickbacks, switching

drugs without informed physician authorization, and other misrepresentations and omissions the

Defendant Manufactnrers made and/or caused to be made a false statement or record.

665.

By failing to disclose and actively concealing that claims submitted to

insmers

were for prescription drugs provided to patients as a result of kickbacks, switching drugs without

informed physician authorization, and other misrepresentations and omissions the claims the

137

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