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102.

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.

103.

Pfizer

representatives

often

visited

Omnicare

locations

for

the

purpose

of

promoting

the

switches.

Pfizer

developed

special

materials

targeted

solely

to

Omnicare

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

Lipitor.

104.

Pfizer's

marketing

personnel

met

with

Omnicare

pharmacists

before

the

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

payors money.

105.

Pfizer also made marketing agents available to Omnicare pharmacists who needed

subsequent technical assistance to switch patients from other statins to Lipitor.

106.

Pfizer

also

worked

with

Omnicare

to

illegally

solicit

PALs

from

physicians

authorizing blanket switches to Lipitor.

Pfizer's actions in furtherance of this conspiracy

included:

  • 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:

29

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