Pfizer executives at the time period of the development and implementation of the
Lipitor scheme included but were not limited to J. Patrick Kelly, Pfizer's then-current Vice
President for Worldwide Marketing, Craig Hopkinson, a specialist in Lipitor marketing; Ken
Solomon; and Chris Chapman.
pharmacists and physicians in Omnicare-serviced nursing homes to "educate" these audiences on
the importance of the switching program and on how to switch patients from other statins to
commencement of mass switching to Lipitor to educate pharmacists on how to make the
switches. Meetings were held with Omnicare staff where Pfizer's marketing staff informed
Omnicare's front line pharmacists and pharmacy supervisors that the switches were not only
going to be beneficial to patients in Omnicare-serviced long-term care facilities, but would save
Pfizer also made marketing agents available to Omnicare pharmacists who needed
subsequent technical assistance to switch patients from other statins to Lipitor.
authorizing blanket switches to Lipitor.
Pfizer's actions in furtherance of this conspiracy
Makingfalse statements to Omnicare Font line pharmacy personnel as to the reason jw the switching. Pfizer made false representations to Omnicare pharmacy staff, through materials prepared uniquely for Omnicare staff, through "kickoff' and other meetings designed to maximize the wholesale switching, and through making themselves available for technical consultations. These false representations included: