December 4, 1995
                COMPLAINTS AGAINST

             State Farm Insurance Companies:
             State Farm Indemnity Company,
             40 West Century Road
             Paramus NJ 07652
     And
             Jane Savastano, Sandra Romei, Veronica Wade,
             Idiana Murray, individually and as agents,
             servants and/or employees of
             State Farm Insurance Company.

     By
             Dr. William C. Hammel
             219 Teaneck Road
             Ridgefield Park NJ 07660
             (201) 807-0652

     On behalf of Myself

     Dear Sirs:

          Whenever "State Farm" is  used  it  will  mean  "State  Farm
     Insurance  Companies: State Farm Indemnity Company, their agents,
     servants and/or employees."

          On September 16, 1994, Mr. Bellamente and I were covered  by
     State  Farm  policy, number X14107-A12-30 covering a 1992 Mercury
     Grand Marquis, bearing New Jersey registration plates WH AB.   We
     had  elected  the  highest  priced  P.I.P. coverage possible; our
     policy  was  paid  up  to  date.   On  September  16,  1994,  Mr.
     Bellamente  and  I  were both injured in an accident while in the
     aforementioned vehicle.  As we were turning into our driveway  we
     were  struck  in  the  rear.  All appropriate filings and reports
     were made in a timely way.  Although we were both injured in this
     accident,  here,  it  is  my  own  injuries  and  subsequent  ill
     treatment and the lack of treatment about which I complain.

          At the time of the accident of September  16,  1994,  I  was
     sufficiently  concerned  with  Mr.  Bellamente's  disorientation,
     nausea, and pain, that I immediately called the  Ridgefield  Park
     Police,  and  Mr.  Bellamente was taken by ambulance to Holy Name
     Hospital with nausea, disorientation and severe pain in his  neck
     and  back.  I followed the ambulance to the hospital and remained
     while he was treated.  When he was released I drove him home.  It
     was only later when he was resting that it became apparent that I
     also was not as well off as I thought.   During  the  night,  the
     pains  of  neck, back and right shoulder became quite intense and
     sleep disturbing.  On waking in the morning, I could scarcely get
     out of bed, and saw My chiropractor Dr. Peter N. Boulukos.

          Since it has been my custom for a good many  years  to  keep
     myself  in  shape  through  regular  cardiovascular  workouts and
     weight training, it was also my custom as it is with  many  other
     weight training people, to have periodic tune up adjustments by a
     good chiropractor.  I managed  to  get  to  my  chiropractor  Dr.
     Boulukos' office that very day, September 17, 1995, at which time
     he took a complete spinal x-ray  series.   These  demonstrated  a
     reversal of curvature in the neck, and a rather disturbing series
     of  subluxations  that  made  the  lumbar  spine  look   like   a
     step-ladder.   Neither one of these configurations was present in
     the preliminary spinal x-rays that Dr. Boulukos  takes  with  any
     new  patient,  when I first saw him back in the '80s.  I have not
     been in  any  automobile  accident  or  had  any  other  kind  of
     traumatic injury in well over 30 years.  My blood pressure at the
     time before the accident was consistently  in  the  120/80  range
     with the low pulse rate of someone who exercises regularly.

          Chiropractic   care   seemed   the   most   reasonable   and
     conservative course of treatment at the time.  I saw Dr. Boulukos
     three to four times a week, and although the progressive recovery
     was slow and with fluctuations, it was real.  The slowness of the
     recovery was undoubtedly due to the fact  that  my  partner,  Mr.
     Bellamente,  and  I both ran a new retail business, a video store
     and were both damaged in the  aforementioned  accident.   Staying
     home,  staying  in  bed  were  not  options.   Wearing  a wide 6"
     weightlifting belt cinched very tightly allowed  me  walk  almost
     like  a  human  being,  and  therefore to walk to and stay at the
     store for a  few  hours  at  a  time.   The  pain,  however,  was
     completely  continuous.   I  also  had  a  computer  software and
     consulting business.  Once again, "calling in sick"  was  not  an
     option.  Ultimately I had to abandon the computer work, while Mr.
     Bellamente and I struggled to maintain the video business.

          On February 15, 1995, I was examined, in accordance with  an
     IME demand by State Farm, by Dr. James F. Linder.  His report was
     received by State Farm according to their stamp, on February  21,
     1995.   I  received a letter, dated April 28, 1995, 71 days after
     the examination, and signed by Jane Savastano  claims  specialist
     for  State  Farm,  which  referenced  and  enclosed a copy of Dr.
     Linder's report, which is in my possession and the possession  of
     my attorney.  The letter from State Farm also states:

          "We will be requesting  another  independent  exam  shortly,
          regarding your treatment."

          I quote Dr. Linder's  diagnoses  contained  In  his  report,
     dated February 16, 1995:

          1) Cervical Whiplash Injury with
             Chronic Cervical Sprain/Strain

          2) Myofascial Pain Syndrome - Cervical

          3) Muscle Tension Headaches secondary to #2

          4) Lumbar Sprain/Strain

          5) Myofascial Pain Syndrome - Lumbar

          6) Lumbar Instability


          In his report, Dr. Linder States further:

          "The opinions expressed in this report are  based  upon  the
          history  of  the  injury  as  presented  by the patient, the
          patient's medical history and  examination  findings  and  a
          review of the x-rays presented by the patient.

          "Mr Hammel is currently  experiencing  the  residuals  of  a
          posttraumatic injury to the neck and back which are causally
          related to the motor  vehicle  accident  which  occurred  on
          9/16/94.   It  is  my  professional  opinion that Mr. Hammel
          would benefit from an  additional  8  weeks  of  care  at  a
          frequency  of  2/week  at  which  time the patient should be
          re-evaluated.  In addition to chiropractic manipulation  and
          appropriate  physical therapy modalities when necessary, his
          treatment program should include  stretching  exercises  for
          the  involved  cervical  and  lumbar musculature, along with
          cervical and lumbar stabilization exercises."


          On May 3, 1995, I was once  again  examined,  in  accordance
     with  an  IME  demand by State Farm, by Dr. James F. Linder.  His
     report was received by State Farm according to their stamp on May
     17,  1995.   I received a letter dated July 27, 1995, enclosing a
     copy of Dr. Linder's second report dated May 3, 1995, which is in
     my  possession  and  the  possession of our attorney.  The second
     paragraph of this letter from State Farm signed by Jane Savastano
     states in its entirety:

          "In the doctor's opinion, no further treatment is  necessary
          as a result of your September 16, 1994 accident.  We will be
          unable to consider any further expenses after July 26, 1995.
          If  there  are  any unpaid bills, please send them to me for
          consideration of payment."

          THIS OPINION WAS IN NO WAY, NOR AT AT ANY PLACE,  STATED  OR
     IMPLIED IN DR. LINDER'S REPORT!  The letter written and signed by
     Jane Savastano, which I have in my possession and which is in the
     possession of our attorney, was a lie.

          In  fact,  the  section  of  his  report  entitled,  PRESENT
     DIAGNOSTIC IMPRESSION (May 3, 1995), reads in its entirety:

          1) Cervical Whiplash Injury
             Chronic Cervical Sprain/Strain

          2) Cervical Spondylosis with Central Canal and Right
             Lateral Recess Stenosis C4-C5, C5-C6, and C6-C7

          3) Myofascial Pain Syndrome - Cervical

          4) Chronic Low Back Pain Secondary to Ligamentous
             Instability and aggravated by the Motor Vehicle
             Accident

          5) Lumbar Spondylosis with Posterior Disc Bulging and Likely
             small Disc Herniation at L5-S1 and Diffuse Disc Bulge at
             L2-L3 through L4-L5 with Borderline Central Canal Stenosis
             at L2-L3.

          6) Myofascial Pain Syndrome - Lumbar

          7) Right A/C Degenerative Changes - Rule out Impingement Syndrome


          Furthermore Dr. Linder's following and  terminal  DISCUSSION
     section,  in which he states his true opinions, I will also quote
     in its entirety:

          "The opinions expressed in this report are  based  upon  the
          history  of  the  injury  as  presented  by the patient, the
          patient's medical history and  examination  findings  and  a
          review of the radiographs presented by the patient.

          Mr.  Hammel  has  indicated  that  there  continues  to   be
          improvement with an overall decrease in the scope, intensity
          and frequency of his and back pain, but that there has  been
          an  increase  in  the  pain in the right shoulder.  It is my
          opinion that Mr.  Hammel  would  continue  to  benefit  from
          additional care at a frequency of no more than 2 time a week
          for 6 weeks and once a week for 6 weeks.   The  patient  has
          indicated that he has been placed on a very limited exercise
          program consisting of some lumbar stretching exercises.  The
          exercise program should be expanded to include stabilization
          exercises for both the lumbar and cervical spine regions.

          "In addition, I  would  reccommend  [sic]  that  Mr.  Hammel
          undergo  an orthopedic evaluation to rule out an impingement
          syndrome and to assess whether this condition is related  to
          the  motor vehicle accident in question or whether there was
          pre-existing  pathology  which  is   contributing   to   the
          dysfunction."

          Before the first examination by Dr. Linder, I had not known,
     nor known of Dr. Linder, nor met, nor ever seen him.

          I emphasize that I had, and continued to have no problems or
     disagreements  with Dr. Linder personally, nor with either of his
     thoroughly professional examinations,  nor  with  either  of  his
     thoroughly professional reports.

          I called Jane Savastano at 1:55 PM on Monday July 31,  1995,
     in  order  to  discuss the contradiction in her letter dated July
     27, 1995 of Dr. Linder's May 3rd report.  She was, of course, not
     available, and I received no callback.  I called again at 2:30 PM
     the same day and received no callback.  I called again  somewhere
     before  3:40  PM,  making  it perfectly clear that I was going to
     make an extreme pest of myself until I spoke with her.  She spoke
     with  me,  and I explained the ridiculousness of the letter.  She
     said not to worry that it was just a formality  and  didn't  mean
     anything.   This  was  also  clearly  a lie, since NOTHING, to my
     knowledge, has been paid by State Farm since.

          Dr. Boulukos, Dr. Kluger, Dr. Schmaus, Dr.  Sender  and  Dr.
     Savatsky,  out  of  kindness and professional concern, have still
     given me medical attention despite State Farm's  intentional  and
     premeditated delinquency and dishonesty.

          I seek payment to these people for  their  medical  services
     together with the interest that is due them by law.

          Since the time of the benefit denial letter (July 26  1995),
     I  continue  to  have  incapacitating episodes of severe back and
     neck pain and spasm.  The shoulder inflammation, as it turns  out
     of  the  rotator  cuff, has flared up so severely that it, caused
     many sleepless nights and  took  many  weeks  of  high  doses  of
     anaprox  (sodium  naprocyn)  to  bring it under control.  I still
     have a residual malfunction  of  the  shoulder,  which  has  been
     diagnosed  by  both Dr. Peter H. Schmaus and Dr. Gary Savatsky as
     frozen shoulder syndrome, the result of tendonitis caused by  the
     accident of September 16, 1994, for which they have both given me
     prescriptions, which are in my possession and in  the  possession
     of  our  attorney, for physical therapy.  I have not been able to
     obtain this needed therapy which was also indicated as  necessary
     by  Dr.  Linder,  State  Farm's  own  examiner  as well as by Dr.
     Schmaus and Dr. Savatsky.

          Since  State  Farm  continues  to  deny  me   any   benefits
     whatsoever,  with  not  one  shred  of  evidence of any kind that
     denial is appropriate,  I  still  suffer  with  a  malfunctioning
     shoulder.   I  still suffer from lumber and cervical malfunction,
     which slowly, however, continues to improve, as a consequence  of
     Dr. Boulukos' treatment, for which he has not been paid, by State
     Farm.

          The amount of time, energy, expense and effort that has been
     expended  by  Mr.  Bellamente,  Dr.  Boulukos,  Dr.  Schmaus, and
     myself, in attempting to  induce  State  Farm  to  recognize  and
     rectify its own self-contradiction and to perform its contractual
     duties has been prodigious.  All such attempts have been met with
     lies, evasiveness, avoidance and complete intransigence.

          I have repeatedly  pointed  out  that  Dr.  Linder's  second
     report  contains no reason whatever for denial of benefits, to no
     avail.  I still continue treatments  with  Dr.  Boulukos  because
     they are still necessary.

          Letters and  phone  calls  to  State  Farm  by  me,  by  Mr.
     Bellamente  and  by  Dr.  Boulukos  have  produced  no  response.
     Letters sent  to  State  Farm  have  consistently  been  lost  or
     misplaced,  or "not received", or simply ignored.  Phone calls to
     "Claims Specialists" produce no return calls.  A claim  file,  or
     so  I  am told by the Claims Specialists, and/or there assistants
     and/or secretaries, apparently requires days going into weeks, to
     find  or retrieve.  My credulity fails on this point.  The person
     whose name is on any correspondence is always, on  another  line,
     not at her desk, not available, at a meeting, not in for the day,
     or has just left.  Repeated attempts at contact  simply  resulted
     in surly and/or downright rude responses from various secretaries
     and/or assistants.

          State Farm has either been totally silent or  simply  issued
     edicts  and  commands  consistent  with  the  high commands of an
     irresponsible  fascist  bureaucracy.   and  has  been   otherwise
     consistently inaccessible and evasive with any attempt to counter
     their assertions and denial of benefits.

          It is clear at this point that this  intransigence  must  be
     dealt with through some other channel.

          It is clear that I am not dealing  with  some  oversight  or
     some  excusable failure to act in a timely way.  With State Farm,
     I am dealing with,  at  very  least,  negligent  and  intentional
     fraud, to deny me the P.I.P. benefits that we have paid for.

          It is also  clear  that  this  fraud  is  conspiratorial  in
     nature, and most probably rampant.  Further indication of this is
     the following:


          Apparently, finally realizing that they had no  grounds  for
     their  arbitrary  decision  to  deny  benefits,  they  decided to
     provide some.  In a letter from State  Farm  dated  September  21
     1995,  and  signed  by Idiana Murray, another "Claim Specialist",
     another demand  was  made  for  an  other  allegedly  independent
     medical  examination,  this  time  with  one Dr. Harry Merliss of
     Hackensack.  I decided to make extensive investigation that would
     be  statistically  significant  (I am a mathematician among other
     things) of the qualifications and reputation of Dr. Merliss among
     medical   professionals.    It   seems   that   every  healthcare
     professional  I  spoke  with  had  heard  of  Dr.  Merliss.   The
     comments,  all  beginning with a chuckle, ranged from "a favorite
     of the insurance companies", through various horror  stories,  to
     "old  Harry would say you were fine if you had no heartbeat", and
     "even judges laugh at that one".  All  responses  concerning  Dr.
     Merliss   were   of   the   same  kind,  with  not  one  response
     contradicting the  uniform  consensus.   On  the  basis  of  this
     consensus, I believe that State Farm, its agents, servants and/or
     employees knew, or certainly should have known  of  Dr.  Merliss'
     reputation;  and  I  further  believe  that  he  was  selected as
     examiner precisely for his reputation, and  that  his  reputation
     was  based  on  his  actions  in the past.  The obvious intent of
     State Farm, its agents, servants  and/or  employees  is  then  to
     obtain  a  medical  opinion upon which a continued fraud might be
     based and continued.

          Upon receipt of Idiana Murray's letter, I immediately called
     and  wrote  State  Farm  and  told  them  that  Dr.  Merliss  was
     unacceptable   as   an   examiner.    (I   maintain   phone   log
     documentation.)  When  I called Idiana Murray on this matter, she
     was, of course, very busy,  and  I  elected  to  speak  with  her
     assistant.  I was told by her rather insolent assistant that, "We
     decide who is acceptable." My response was, "That may be  but  it
     is  our legal right to refuse this particular examiner." To which
     she responded, "I'm not here to argue with you."  Then  she  hung
     up.   This  was  on  October  18,  1995.   But for another failed
     attempt at telephonic communication on October 20, 1995 that  was
     my last phone contact with anyone at State Farm.  To date we have
     not been contacted in any way by State Farm regarding any  future
     examinations.   Of  course,  no  bills  have been paid, including
     those from before the date of denial.  Payments  for  medications
     have  had  to  come out of our own rapidly diminishing resources,
     the continuing diminishment being caused by arbitrary  denial  of
     benefits and malicious fraud by State Farm.

          Mr. Bellamente and I both work at the same business, a video
     store  which  has  now,  as  a  consequence of State Farm's fraud
     become our only source of income, and  due  to  the  rather  sick
     games  being played by State Farm Insurance, its agents, servants
     and/or employees.  We must  both  work  somehow  or  starve,  and
     decide  on  the basis of who hurts the least at any given moment.
     Even further, to deal almost every day with the  consequences  of
     this  fraud, has caused us on numerous days to abandon the store,
     for an entire day or part of a day  for  medical,  psychological,
     and  legal help as well as having to take the time and expend the
     energy to prepare and assemble documents such at this.

          This drain on our combined time and energy, at a  time  when
     it  can  be least afforded, continues, to this moment, to destroy
     our now only, and insufficient, source of income.  The  financial
     damages  caused  by  malicious  fraud  of State Farm, continue to
     accumulate.  The multitudinous damages, psychological, emotional,
     physical,  and  financial  all worsening as a consequence of this
     fraud have become intolerable.

          The additional  drain  necessitated  by  having  to  respond
     continuously  to the damages and the fraud, as well as the stress
     level caused by not being able or even, permitted by State  Farm,
     to address it all has become intolerable.

          Additionally,   I   now   suffer   psychological   problems,
     completely  new  to  me,  as  a  direct result of the harassment,
     fraud, larceny and their deliberate actions  the  perpetuate  and
     aggravate    the   already   existing   physical   damage.    The
     psychological problems caused by State Farm have  further  caused
     more  life  threatening  physical  problems, which I elaborate on
     below and further caused enough financial problems to  result  in
     imminent  financial  destruction.   I  am  currently, and for the
     first time in my life,  under  the  care  of  a  psychotherapist,
     having  to  take  anxiolytics  and antidepressants to maintain my
     sanity.

          Neither Mr. Bellamente nor I am able to  maintain  order  in
     business,  home,  what remains of personal life and mind.  Though
     we are friends of long standing, we are scarcely able  to  be  of
     assistance to each other.  We do not and cannot manage to cook or
     clean, because of the drain on us  and  damage  done  to  us.   A
     nutritionist  would  gasp  at  our  supposed diet, which consists
     almost totally  of  deli'  food,  sandwiches  and  various  fatty
     salads.   A  consequence  once  again  of having neither time nor
     energy to do otherwise, and the board of  health  would  probably
     condemn  our  quarters.   My  customary exercise program has been
     made impossible by State Farm's harassment, negligence and fraud.
     If  the  necessary  and  appropriate  medical care were provided,
     according to contract, by State Farm, instead of  the  harassment
     and  fraud  that  was,  in fact, perpetrated, and continues to be
     perpetrated, the numerous damages and destruction that  has  been
     wrought would not have occurred.

          Being quite aware  of  my  overall  damaged  and  precarious
     condition  caused  by  the accident of September 16, 1995 and the
     various synergistic damages caused by the fraudulent behavior  of
     State  Farm,  its  agents,  servants  and/or  employees I made an
     appointment to  see  my  internist.   On  that  appointed  visit,
     November  6,  1995 to Paul S. Sender, M.D., my internist of about
     12 years, who prescribes for me, his standard taking of my  blood
     pressure   showed   a  blood  pressure  of  160/80  and  a  pulse
     significantly more rapid than usual.  He has monitored  my  blood
     pressure  and  pulse  over  these  12 years and knows that is not
     normal for me.  He was sufficiently concerned  about  my  current
     psychophysical  state  that  he  ordered a blood workup which was
     performed at 1:00 PM November 13, 1995 by Corning Metpath and  an
     EKG,  that  was  performed  immediately.   In  view of my general
     precarious state caused by State Farm, I was also given influenza
     vaccine.   In agreement with with my psychotherapist, Dr. Kluger,
     Dr.   Sender   immediately   prescribed   an    anxiolytic    and
     antidepressant,  copies  of which are in my possession and in the
     possession of our attorney.

          The EKG unfortunately showed a change from my usual baseline
     EKG that indicating a diagnosis of a silent heart attack.

          The Blood work report which I have in my possession  and  is
     in  the possession of our attorney, showed serum lipid values all
     dangerously above the established reference ranges.  The  overall
     conclusion  of the blood report signed by: Raymond Gambino, M.D.,
     Joseph E. O'Brien, M.D., Paul A. Krieger, M.D.  Kim Lamon,  M.D.,
     and Sherif Nasr, M.D. concludes:

          "THIS  PATIENT'S  SCORE  IS  ASSOCIATED  WITH  THE   HIGHEST
          CORONARY HEART DISEASE RISK."

          Dr. Sender has also  prescribed  medications  to  lower  the
     serum lipid score, particularly the very high cholesterol level.

          I was, of course, horrified, but not completely surprised by
     these  revelations.   If  State Farm, its agents, servants and/or
     employees can keep up their good work, then perhaps they will not
     have  to  pay anything, since certainly, they will surely attempt
     to claim, my death by cardiac arrest cannot be accident related.

          Psychotherapy and psychotropics notwithstanding, I have  now
     become devoid of all patience with this perfectly calculated evil
     and will very  soon  become  devoid  of  all  civility  if  these
     murderous  and thieving troglodytes are not stopped and subjected
     to the most appropriately severe punishment.

          I am, therefore, accusing State  Farm  Insurance  Companies:
     State  Farm  Indemnity,  their agents, servants and/or employees,
     of:

     1)   Intentional, premeditated and calculated Fraud;

     2)   Intentional, premeditated and calculated Breech of contract;

     3)   Reckless endangerment of my life and limb;

     4)   Premeditated and  intentional  calculated  damage  including
          that of possible death;

     5)   Intentional,  premeditated  and  negligent   infliction   of
          irreparable physical damage;

     6)   Intentional, premeditated and negligent infliction,  over  a
          long   period   of  time,  of  severe  mental  distress  and
          harassment, to an extent  that  requires  my  treatment  and
          medication by a physician, a psychotherapist; and

     7)   Intentional,  premeditated  and  negligent   infliction   of
          annihilating financial damage; as well as

     8)   Violations of the Fair Claims Act.


           DAMAGES TO DR. WILLIAM C. HAMMEL IN COMPLAINT AGAINST
       STATE FARM INSURANCE COMPANIES: STATE FARM INDEMNITY COMPANY,
                   IT AGENTS, SERVANTS AND/OR EMPLOYEES.

          Whenever "State Farm" is  used  it  will  mean  "State  Farm
     Insurance  Companies: State Farm Indemnity Company, their agents,
     servants and/or employees."

          I suffer continued impairment  of  R.  Shoulder,  20  to  30
     degrees  loss of ranges of motion, for which physical therapy has
     been prescribed by both Dr. Schmaus and Dr. Savatsky, and  denied
     by State Farm.

          I suffer persisting damage to rotator cuff of  R.  shoulder,
     where  use  causes severe and painful tenosynovitis that can only
     be   treated   with   high   doses   of    prescribed    powerful
     anti-inflammatories  whose  long  term  use  is  known  to  cause
     gastrointestinal, liver and kidney damage.

          I suffer maliciously intentional and negligent infliction by
     State  Farm  and  specifically  by  their agents, servants and/or
     employees Jane Savastano, and Idiana Murray, of mental  distress,
     insomnia,  depression and anxiety so as to require treatment by a
     psychologist and a physician.  The  emotional  and  psychological
     damages  are severe enough to demand prescribed medication in the
     form antidepressants and anxiolytics the  long  term  effects  of
     which are unknown.

          I hold State Farm wholly responsible  for  residuals  and/or
     sequelae  from  the use of the potent medications that I have had
     to be given because of its fraud and the consequences thereof.

          The source of  these  emotional  and  psychological  damages
     being   unwarranted  denial  of  benefits,  their  avoidance  and
     evasiveness with regard to my legitimate  claims,  the  arrogance
     and  surliness  of  their  assistants  and/or  secretaries, their
     mendaciousness, and total lack of response to logic and empirical
     evidence of any nature.

          A  further  source  of  these  emotional  and  psychological
     damages  being  a  protraction  of  recovery  period for physical
     damages  sustained  in  the  accident  of  September  16,   1994,
     inability  to  work  and therefore loss of income from my work as
     systems analyst, computer programmer and consultant.

          A  further  source  of  these  emotional  and  psychological
     damages  being  that I work in pain an restriction in work at the
     one source of insufficient income  that  I  have  left,  a  video
     business, which I will have to sell at a loss.

          A  further  source  of  these  emotional  and  psychological
     damages  being  that  I work and live with Mr. Alan J. Bellamente
     who was also severely injured in the accident  of  September  16,
     1994,  and who has become as unable to maintain house and life as
     I, and who has also been unwarrantedly denied benefits  by  State
     Farm,  and  the  two  people  named above.  I see him deteriorate
     mentally and physically more every day.  I have filed a complaint
     on his behalf because he is presently not able to do so himself.

          I suffer the physical damage of a  significant  rise  in  my
     normal  blood  pressure  from  120/80 to 140/80, and a cardiogram
     that my internist Dr. Paul Sender diagnosis as the result  of  an
     occurrence  of  a  silent  heart  attack, for which I blame State
     Farm.  My previous cardiograms showed no such anomalies.

          I suffer financial damage  from  my  inability  to  maintain
     physically  and  mentally  my  business as computer consultant at
     all, resulting in complete loss of income from that source.

          I suffer financial damage from  my  inability  to  maintain,
     physically  and  mentally, my retail business, and the consequent
     necessity of selling it quickly and at a considerable loss.

          I suffer financial and personal damage from my inability  to
     maintain  my  place  of residence in the State of New Jersey, and
     emotionally, from my dependence on a friend to provide me with  a
     place to live.

          I  demand  immediate  reinstatement  of   P.I.P.   benefits,
     according to contract and the Fair Claims Act.

          I demand compensation, beyond and excluding P.I.P. benefits,
     for  all damages already caused by the unwarranted and fraudulent
     actions State Farm, and all consequences thereof, past,  present,
     and future, and that State Farm cease any and all perpetration of
     further fraud and damage immediately.


         DAMAGES DIRECTLY CAUSED BY THE FRAUDULENCE OF STATE FARM:

             Damages Incurred by any malfeasances
             or civil actions due to my state of
             mind caused by mental, physical,
             emotional and financial abuses of
             State Farm                              $ (unknown)
             Loss of Income from Retail business     $  7000.00
             Loss of Business and Good Will, and
             therefore the value of the business
             caused by closing of business in
             order to address the fraudulence of
             State Farm                              $ 20000.00
             Capital Loss from Sale of Retail
             Business                                $ 70000.00
             Loss of Earnings as Computer
             Consultant, Analyst and Programmer      $ 15000.00
             Loss of Equity in Partially Restored
             Antique Mercedes Benz from forced
             liquidation                             $ 11000.00
             Cost of Relocation                      $  5000.00
             Professional Services incurred by the
             fraudulence of State Farm               $  2500.00

             Subtotal:                               $130500.00

          I further  demand  that  all  future  "Independent"  Medical
     Examinations  be mutually agreed upon, truly independent, and
     not fraudulent farces.


              OUT OF POCKET EXPENSES RELATED TO THE ACCIDENT
                      AND TO THE FRAUD OF STATE FARM:

             Prescribed Medications:                $   290.55
             Subtotal:                              $   290.55


                           UNPAID MEDICAL BILLS:

             Teaneck Radiology                       $   902.00
             Dr. Peter N. Boulukos                   $  2565.00
             Dr. Peter H. Schmaus                    $   321.00
             Dr. Gary Savatsky                       $   150.00*
             Dr. Albert Stabile                      $   180.00
             Dr. Paul S. Sender                      $   250.00*
             Dr. Martin A. Kluger                    $   680.00*
             Subtotal:                               $  4048.00


             Subtotal:                               $  4338.55

             TOTAL:                                  $135129.10 +

     * Not immediately available, and estimated

          I am  demanding  that  these  bills  be  paid  according  to
     contract together with the interest that is due according to law.

          I further demand compensation for the damages done me by the
     intentional,  negligent  and malicious fraud perpetrated by State
     Farm.


___________________________________     ___________________________________

    Dr. William C. Hammel                         Notary Public