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Defendant Manufacturers conspired to submit, and caused to be submitted to insurers contained

false, incomplete and misleading information that was material to the claims. The information

was material because insurers would have wanted to know that the Defendant Manufacturers

were not complying with state insurance, prescription drug switching, and consumer fraud laws.

666.

Insurers were unaware of the falsity of the records, statements and claims made or

caused to be made by the Defendant Manufacturers involving the Defendant Manufacturers'

illegal prescription drug provision at the time the insurers reimbursed the co-conspirator

pharmacies.

667.

Each claim for reimbursement from an insurer that Defendant Manufacturers

conspired to

submit, or caused to be submitted for providing "preferred" prescription drugs

represents a false claim. Each claim for reimbursement for "preferred" drug prescriptions also

represents an unlawful claim and/or a false or fraudulent claim for payment.

668.

Plaintiffs cannot at this time identify all of the false claims for payment that were

caused

by

the

Defendant

Manufacturers'

conduct.

This

information

is

solely

within

the

possession of the Defendant Manufacturers and Omnicare.

JURY DEMAND

669.

Plaintiffs demand trial by jury on all claims.

PRAYER

WHEREFORE, Plaintiffs pray for judgment against the Defendant Manufacturers as follows:

1.

That Defendant Manufacturers be found to have violated and be enjoined from future violations of the federal False Claims Act, 31 U.S.C. §3729-32, the Illinois Whistleblower Reward and Protection Act, 740 ILCS 175, the California False Claims Act, Cal. Gov. Code §12651 (a), the Delaware False Claims and Reporting Act, Del. Code Tit. VI. §120l, the District of Columbia False Claims Act, D.C. Code §2-308.03 et seq.,

138

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