Exhibit C of the RICO Complaint: Hammel v. State Farm and the Amended Complaint
which will be followed in the Diary Page This is a complaint sent to The North Carolina Insurance Department.





                              Dr. WILLIAM C. HAMMEL

                                 General Delivery
                        Robbinsville, North Carolina 28771
                                  (704) 479-1547
                                  (704) 479-1547 FAX



                                                May 29, 1996
          Mr. James E. Long
          Commissioner of Insurance
          Dobbs Building
          430 North Salisbury Street
          PO Box 26387
          Raleigh, NC 27611


          Dear Mr. James,


               This is a complaint, on behalf of  Alan  J.  Bellamente  and

          myself, against State Farm Insurance, particularly naming


               Mr. Jim [sic] Zitney,
               Claims Service Office
               19 Westgate Plaza
               386 Westgate Road
               Franklin NC, 28734

          The complaint is one of conspiracy to commit fraud, and collusion
          in commission and deliberate perpetuation of fraud.


               My business partner Alan J. Bellamente and I,  in  our  1992
          Mercury   Grand  Marquis,  were  turning  into  our  driveway  on
          09/16/96, in Ridgefield Park, New Jersey, when we were struck  in
          the  rear  by  another  vehicle.  Mr. Bellamente was taken to the
          hospital immediately, my injuries showed themselves hours after.

               We  were  both  covered  by  no-threshold  personal   injury
          protection,  the  most  expensive type of protection permitted by
          New Jersey's "no fault" law, under policy  number  X17410730 001,
          issued  by  State  Farm  Indemnity  of  New  Jersey.  We received
          appropriate  and  prudent  treatment,  paid  for  by  State  Farm
          Indemnity  of  New  Jersey, until September 20, 1995, when P.I.P.
          benefits were wrongly terminated.

               We both worked as best we could, relieved on a few occasions
          by friends; being self-employed there was not much choice.

               Various problems arose  from  the  accident  injuries:  time
          spent away from business, having to close it on some days, due to
          treatment requirements, inability to work, etc.  The accumulation
          of  sequelae  from  the accident became overwhelming.  We finally
          arranged with friends to cover for us while we both got away  for
          a  week for some badly needed physical and mental rest.  For this
          rest period, I  chose  the  Southern  Mountain  Region  of  North
          Carolina.   On return from North Carolina, Mr. Bellamente was, on
          the instruction of his primary surgeon  Dr.  Rubin,  to  schedule
          surgery  within  two weeks, and immediately begin the appropriate
          preparations for surgery.

               Quite a while before leaving for North Carolina, it had been
          ascertained  using  extensive  radiological  and  EMG studies, by
          three preeminent physicians in Bergen  County,  New  Jersey;  Dr.
          Adams,  a  neurologist, Dr. Pojedinec, an orthopedic surgeon, and
          Dr. Rubin, a neurosurgeon that surgery was definitely  indicated,
          that  there  was  at  least  one,  possibly  three  cervical disc
          herniations, causing impingement on the spinal  cord  itself,  as
          well  as  foraminal  encroachments;  and  furthermore, that their
          prognosis without the surgery would probably  be  paralysis  from
          the neck down.

               It had also been ascertained, by radiological studies,  that
          I had suffered various lumbar dislocations not present before the
          accident, which are difficult to stabilize; a  damaged  shoulder,
          and damaged cervical area.

               Mr. Bellamente and I both functioned, as necessity dictates,
          in  continuous  pain,  and  severe  distress.   We both remain in
          continuous pain, and in severe distress to this moment.  We  both
          function  still  to  the  best  of our very limited abilities, as
          necessity dictates, in continuous pain and severe distress.

               The trip to North  Carolina  was  at  least  psychologically
          beneficial.  Both Mr. Bellamente I, quite literally, fell in love
          with the mountains, and with the people.

               On returning to New Jersey, we discovered  that  State  Farm
          Indemnity  had terminated all benefits, and that Mr. Bellamente's
          surgery would not,  therefore,  take  place.   My  treatment  and
          further diagnosis was prevented.

               Both Mr. Bellamente and I, being unable to work,  unable  to
          maintain  concentration,  suffering  frequent memory loss, and in
          constant physical and mental distress, as direct  consequence  of
          the  accident  of  September  16,  1994  and  also  as  a  direct
          consequence of the fraud being perpetrated on us  by  State  Farm
          Indemnity  of  New  Jersey, decided we had to extricate ourselves
          from the conditions that  were  literally  killing  us  both,  no
          matter  what.  (Among other things, on 11/06/95 it was discovered
          by EKG that I had suffered a complete left  bundle  branch  heart
          block  as  a  consequence of the continuing and escalating stress
          caused by the fraud of State Farm Indemnity of New  Jersey.)  The
          place  that  Mr.  Bellamente  and  I  fled to was, of course, the
          Southern Mountain Region of North Carolina.

               Since  escaping  from  New  Jersey  to  North  Carolina,  My
          Business  valued  at  $90,000.00  has been essentially stolen and
          destroyed, and an undefendable antique Mercedes Benz  vandalized;
          and  other  personal property lost to me.  Mr. Bellamente's house
          is currently being sold at a sheriff's auction, and the physical,
          emotional,  psychological,  and  financial  destruction caused by
          State Farm Indemnity of New Jersey continues.

               The record of the sequence of events up to December 4,  1995
          is  contained  in the accompanying complaints that I submitted on
          that date to the New Jersey Department of  Insurance,  wherein  I
          have  presented  facts  and  arguments  substantiating  claims of
          various illegalities, the most serious of which  is  intentional,
          premeditated  and calculated fraud.  against State Farm Indemnity
          of New Jersey, and against named agents, servants and employees.

               The original single claim number, 30-3204-312, has now  been
          split  into  two  claim  numbers,  and are now 30-3204-312-AB and
          30-3204-312-WH.

               The investigatory  arm  of  the  New  Jersey  Department  of
          Insurance  is  the New Jersey Commission for Insurance Protection
          and Enforcement.

               Case numbers: 95-78255 (Alan J. Bellamente)
                             95-78257 (William C. Hammel)
               Investigator: Mr. Robert Only
               Telephone:    (609) 292-5316
                             (609) 292-5865 FAX

          The investigation by the Department of Insurance of New Jersey is
          still continuing.

               State Farm Indemnity has, on information  and  belief,  sent
          all  claim  documents to the State Farm office at Franklin.  This
          was not done at my request, nor at Mr. Bellamente's request.  Why
          this was done we do not know.

               State Farm in North Carolina,  through  its  agent,  servant
          and/or employee Jim [sic] Zitney, has already been abusive to Mr.
          Bellamente, and has told  him  that  "we  will  not  do  anything
          without instructions from Paramus."(New Jersey).

               On  information  and  belief,  State  Farm  Indemnity  is  a
          separate  entity,  established  in  the  State  of New Jersey, by
          special provision of the New Jersey  Insurance  Commission,  when
          State Farm threatened to cease writing automobile policies in New
          Jersey,  claiming  their  costs  of  writing  such  policies  was
          detrimental  to  State  Farm as a whole.  Further, on information
          and belief, State Farm Indemnity is licensed only in the State of
          New  Jersey,  and distinct from the entity, State Farm Insurance,
          in North Carolina.  In short, State Farm in North Carolina is  in
          collusion  with  State  Farm  Indemnity  of  New  Jersey  in  the
          perpetration of fraud,  and  is  conspiring  to  perpetuate  this
          fraud.

               I am requesting an investigation of this matter, and  relief
          and compensation to Mr. Bellamente, and to me for the additional,
          continued and exacerbated damages and  injuries  that  are  being
          caused  by  this conspiracy and collusion by State Farm Insurance
          in North Carolina with State Farm  Indemnity  of  New  Jersey  to
          commit  fraud,  as  well  as conspiracy in the other illegalities
          listed in the complaints to the Department of  Insurance  of  the
          State of New Jersey.

               I am sending a copy of this letter to the investigator,  Mr.
          Robert Only in New Jersey.

               As far as I know, Mr. Zitney is in possession of a  copy  of
          the  entire  file  from  State  Farm Indemnity of New Jersey.  If
          there are any documents whose existence is  clear  but  that  you
          cannot  obtain,  should I have them, copies are at your disposal.
          I have copies of all medical and radiological reports.

                                        Sincerely,

                                        Dr. William C. Hammel

          Enclosed:
               Two Complaints to
               The Department of Insurance of New Jersey;
	       [Exhibit A]
	       [Exhibit C]

               Copies of two Letters of Mr. Zitney;

               Copies of letters of denial of benefits sent
               by Mr. Zitney (originally from State Farm Indemnity).




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The URL for this document is:
http://graham.main.nc.us/~bhammel/RICO/ExhibitC.html
Created: February 4, 2000
Last Updated: May 28, 2000