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schizophrenia and other severe mental health conditions. Competing drugs include Risperdal

and Zyprexa. Bristol Myers and Omnicare conspired to switch many atypical antipsychotic

prescriptions for Omnicare-serviced patients from Risperdal and other atypical antipsychotics to

Abilify.

174.

Bristol

Myers'

executives

at

the

time

period

of

the

development

and

implementation of the Abilify scheme included but were not limited to, Robert W. McBrier,

Thomas Libassi, Matthew Kryczko, Jackly Bryon, John E. Hanson, Maryann Giorgianni, Leslie

T. Hirsch, Director of Managed Care Operations, Frances E. Hamer, John V. Mollica, and

Sandra E. Pittman.

175.

Bristol Myers' representatives often visited Omnicare locations for the purpose of

promoting the switches. Bristol Myers 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 Risperdal and other

atypical antipsychotics to Abilify - including, potentially - many patients who had previously

been switched from atypical antipsychotics to Risperdal previously.

176.

Bristol

Myers'

marketing personnel

met with Omnicare

phannacists

before

the

commencement of mass switching to Abilify to educate pharmacists on how to make the

switches. Meetings were held with Omnicare front line staff where Bristol Myers' marketing

staff informed Omnicare's front line pharmacists and phannacy 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.

177.

Bristol Myers also made marketing agents available to Omnicare pharmacists who

needed subsequent technical assistance to switch patients from Risperdal and other atypical

48

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