By effectuating a similar PAL letter solicitation-for-kickback scheme, Janssen and
Omnicare conspired to defraud the State of Florida by submitting false claims and causing the
submission of false claims for Risperdal and other drugs.
As a result of the claims for reimbursement defendants caused to be submitted to
Florida Medicaid, which were certified compliant with federal and state Medicaid law and
regulation as a condition of payment by co-conspirator pharmacies, Florida regularly made
payments to pharmacies for Defendant Manufacturers' illegally switched drugs.
The amounts of the false or fraudulent claims to the State of Florida were
Plaintiff State of Florida, 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
termination with Omnieare.
COUNT XV Georgia State False Medicaid Claims Act Ga. Code 49-4-168 et seq. (Against All Defendants)
Plaintiffs reallege and incorporate by reference Paragraphs 1-261 set forth above.
This Count is brought by Lisitza in the name of the State of Georgia under the qui
tam provisions of the Georgia State False Medicaid Claims Act, Ga. Code 49-4-168 et seq.
pharmaceuticals in the State of Georgia. Omnicare, at all times relevant to this action, has
operated and continues to operate pharmacies in the State of Georgia.