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the false records and statement were made to the government, and the jointly-funded Medicaid

Program was deprived of the much-needed appropriate Rebate payments result of the Defendant

Manufacturers' intentionally inaccurate quarterly reporting of best price.

289.

Other federally funded healthcare such as FSS and PHS entities were also harmed

by Defendant Manufacturers' concealment of their true best prices.

290.

By

virtue

of

the

false

records

or

statements

made

or

used

by

the

Defendant

Manufacturers, the United States has suffered damages and therefore is entitled to multiple

damages under the False Claims Act, to be determined at trial, plus a civil penalty of $5,500 to

$11,000 for each such false statement made or used by the Defendant Manufacturers.

291.

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 northern lllinois 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

the government exceeds $10 million.

COUNT IV Conspiracy to Submit False Claims 31 U.S.c. §3729(a)(3) (Against All Defendants)

  • 292.

    Plaintiffs reallege and incorporate by reference Paragraphs 1-261 set forth above.

  • 293.

    By effectuating the PAL letter solicitation-for-kickback scheme detailed herein,

Bristol Myers and Omnicare conspired to defraud the government by submitting false claims and

causing the submission of false claims for Monopril, Abilify, and other drugs.

294.

By effectuating a similar PAL letter solicitation-for-kickback scheme, Pfizer and

Omnicare conspired to defraud the government by submitting false claims and causing the

75

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