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367.

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 District of Columbia, for Risperdal

and other drugs.

368.

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 District of Columbia, for Lipitor, Accupril,

and other drugs.

369.

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 canse to be submitted false or fraudulent claims for payment or approval,

directly or indirectly, to officers, employees, or agents of the District of Columbia, for Levaquin,

Ultram/Ultracet, and other drugs.

370.

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

District of Columbia Medicaid, which were certified compliant with federal and state Medicaid

law and regulation as a condition of payment by co-conspirator pharmacies, District of Columbia

regularly made payments to pharmacies for Defendant Manufacturers' illegally switched drugs.

371.

The amounts of the false or fraudulent claims to the District of Columbia were

material.

372.

Plaintiff District of Columbia, being unaware of the falsity of the claims and/or

statements made by defendant, and in reliance on the accuracy thereof paid and may continue to

88

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