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pay for Defendant Manufacturers' "preferred" drugs. All unlawful conduct described above may

have continued after Lisitza's termination with Omnicare.

COUNT XII Conspiracy to Submit False Claims In Violatiou of the District of Columbia False Claims Act

  • D.

    C. Code §2-308.14(3)

    • 373.

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

    • 374.

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

Bristol Myers and Omnicare conspired to defraud the District of Columbia by submitting false

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

375.

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

Omnicare conspired to defraud the District of Columbia by submitting false claims and causing

the submission offalse claims for Lipitor, Accupril and other drugs.

376.

By

effectuating

a

similar

PAL

letter

solicitation-for-kickback

scheme,

Ortho

McNeil and Omnicare conspired to defraud the District of Columbia by submitting false claims

and causing the submission of false claims for Levaquin, UltramlUltracet, and other drugs.

377.

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

Omnicare conspired to defraud the District of Columbia by submitting false claims and causing

the submission of false claims for Risperdal and other drugs.

378.

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

the 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, the

District of Columbia regularly made payments to pharmacies for Defendant Manufacturers'

illegally switched drugs.

379.

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

89

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