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344.

Bristol

Myers,

Janssen,

Ortho

McNeil,

and

Pfizer,

at

all

times

relevant to

this

action, sold and continue to sell pharmaceuticals in the State of Delaware.

345.

At

all

times

relevant

and

material

to

this

Amended

Complaint,

the

Defendant

Manufacturers Bristol Myers, Ortho McNeil, Janssen, and Pfizer knowingly caused false claims

for payment or approval, in the form of false cost information for their "preiim-ed" medications

specified herein, as well as other medications manufactured by them, to be presented to officers

and

employees

of

the

federal

and

state

governments.

As

a

result,

the

federal

and

state

governments paid reimbursements for the Defendant Manufacturers' drugs to Omnicare and

other Medicaid provider pharmacies sums of money grossly in excess of the amounts

contemplated by law, resulting in great financial loss to the federal and state governments.

346.

By virtue

of the

above-described

acts,

among others,

Defendant

Bristol

Myers

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 Delaware, for Monopril,

Abilify, and other drugs.

347.

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 Delaware, for Risperdal

and other drugs.

348.

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

84

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