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material.

380.

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

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' improperly switched

prescriptions.

All

unlawful

conduct

described

above

may

have

continued

after

Lisitza's

termination with Omnicare.

COUNT XIII Florida False Claims Act FI. Stat. §§68.081-68.09 (Against All Defendants)

  • 381.

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

  • 382.

    This Count is brought by Lisitza in the name of the State of Florida under the qui

tam provisions of Florida False Claims Act, Fl. Stat. §§68.08l-68.09.

383.

Omnicare,

at

all

times

relevant

to

this

action,

sold

and

continues

to

sell

pharmaceuticals

in

the

State

of

Florida.

Omnicare,

at

all

times

relevant

to

this

action,

has

operated and continues to operate pharmacies in the State of Florida.

384.

Bristol

Myers,

Janssen,

Ortho

McNeil,

and

Pfizer,

at

all

times

relevant

to

this

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

385.

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 "preferred" medications

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

and

employees

of

the

federal

and

state

govermnents.

As

a

result,

the

federal

and

state

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

90

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