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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.

COUNT VI Conspiracy to Submit False Claims in Violation of the Illinois Whistleblower Reward and Protection Act 740 ILCS 175/3(3) (Against All Defendants)

  • 313.

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

  • 314.

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

Bristol Myers and Omnicare conspired to defraud the State of Illinois by submitting false claims

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

315.

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

submission offalse claims for Lipitor, Accupril and other drugs.

316.

By

effectuating

a

similar

PAL

letter

solicitation-for-kickback

scheme,

Ortho

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

causing the submission of false claims for Levaquin, Ultram/Ultracet, and other drugs.

317.

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

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

submission offalse claims for Risperdal and other drugs.

318.

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

79

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