33.

However , the r eason for the "explosive gr owth" of other

Rheumatology sales teams at that point in time was due, in
par t, to MALLINCKRODT r equesting that its r epr esentative
pr omote the Acthar dr ug in an illegal, off-label manner .
35. Fr anks was clear that he would not engage in illegal
activities to incr ease sales... Despite this, and being advised
that employees wer e told by compliance to not to "put anything
in wr iting" ...
37. "A similar push and ack nowledgement that to k eep his job,
Fr anks essentially had to push in off-label ar eas..."
40. Fr anks is infor med and believes that ther e wer e illegal
sales pr actices being committed in other r egions...

42. Fr anks was also awar e of other compliance r elated issues

at MALLINCKRODT, which Fr anks is infor med and believes and
ther eon alleges that these issues include but ar e not limited to:
potentially insur ance/ Medicar e fr aud r elated to the r efills as
noted above, HIPAA violations wher e four or eight week
pr escr iptions wer e pr ovided wher e ther e was no patient visit ...
This was done to "game the system" and potentially commit
insur ance/ Medicar e fr aud.)

/ wp-content/ uploads/ 2017/ 06/ MNK-Franks-Complaint-7-2016-1.pdf

While the exact way that Acthar works in the body is unknown, further
studies are being conducted.

Then why did the nations most pre

s
of Turings s price.