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the govermnent, and possibly continues to cause false records or statements to get false or

fraudulent claims paid or approved, directly or indirectly, to officers, employees, or agents of the

United States, for Risperdal and other drugs.

277.

By virtue of the above-described acts, among others, Pfizer knowingly caused to

be made or used, false records or statements to get false or fraudulent claims paid or approved by

the government, and possibly continues to cause false records or statements to get false or

fraudulent claims paid or approved, directly or indirectly, to officers, employees, or agents of the

United States, for Lipitor, Accupril, and other drugs.

278.

By virtue of the above-described

acts,

among others,

Ortho McNeil

knowingly

caused to be made or used, false records or statements to get false or fraudulent claims paid or

approved by the government, and possibly continues to cause false records or statements to get

false or fraudulent claims paid or approved, directly or indirectly, to otlicers, employees, or

agents of the United States, for Levaquin, Ultram/Ultracet, and other drugs.

279.

The amounts of the false or fraudulent claims to the United States were material.

280.

Plaintiff United States, being unaware of the falsity of records or statements

caused to be made by the Defendant Manufacturers, and in reliance on the accuracy thereof paid

and may continue to pay for the Defendant Manufacturers' "preferred" drugs. All unlawful

conduct described above may have continued after Lisitza's termination with Omnicare.

281.

From 1998 to the date of this Complaint, by reason of the conduct described

above, the government has been damaged in an amount that is believed to be in excess of $3.5

million from Omnicare's nOlthern Illinois facilities alone. As the Defendant Manufacturers'

fraudulent practices extend throughout the country in states where government reimbursement

rates make such fraud lucrative for the Defendant Manufacturers; the amount of total damages to

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