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Abilify, and other drugs.

307.

By

virtue

of

the

above-described

acts,

among

others,

Defendant

Janssen

knowingly caused to be presented false or fraudulent claims for payment or approval, and

possibly continues to cause to be submitted false or fraudulent claims for payment or approval,

directly or indirectly, to officers, employees, or agents of the State of Illinois, tor Risperdal and

other drugs.

308.

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

caused to be presented false or fraudulent claims for payment or approval, and possibly

continues to cause to be submitted false or fraudulent claims for payment or approval, directly or

indirectly, to officers, employees, or agents of the State of Illinois, for Lipitor, Accupril, and

other drugs.

309.

By virtue of the above-described acts, among others, Defendant Ortho McNeil

knowingly caused to be presented false or fraudulent claims for payment or approval, and

possibly continues to cause to be submitted false or fraudulent claims for payment or approval,

directly or indirectly, to officers, employees, or agents of the State of Illinois, for Levaquin,

Ultram/Ultracet, and other drugs.

310.

As a result of the claims for reimbursement defendants caused to be submitted to

Illinois Medicaid, which were certified compliant with federal and state Medicaid law and

regulation as a condition of payment by co-conspirator pharmacies, Illinois regularly made

payments to pharmacies for Defendant Manufacturers' illegally switched drugs.

311.

The

amounts

of

the

false

or

fraudulent

claims

to

the

State

of

Illinois

were

material.

312.

Plaintiff State of Illinois, being unaware of the falsity of the claims and/or

78

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