UNITED STATES DISTRICT COURT
        WESTERN DISTRICT OF NORTH CAROLINA
	BRYSON CITY DIVISION

        ____________________________________________
                                                   |
             WILLIAM C. HAMMEL,                    |
             ALAN J. BELLAMENTE,                   |
             et al.,                               |      MEMORANDUM ON
                                                   |  MEDICAL PAPER REVIEWS
                  Plaintiffs                       |   AND AN IME REPORT
                                                   |      BY DEFENDANT
                   vs.                             |   ERIC L. FREMED, M.D.
                                                   |
             STATE FARM MUTUAL AUTOMOBILE          |
             INSURANCE CO.,                        |      No. 2:99:CV-44-T
             STATE FARM INDEMNITY COMPANY,         |
             et al.                                |
                                                   |
                  Defendants                       |
        ___________________________________________|

        SHORT CAPTION: HAMMEL v STATE FARM



	Memorandum Concerning an IME Report and Various Paper Reviews
	by Defendant Eric L. Fremed, M.D., on the Medical Reports by
	Physicians Treating both Plaintiffs.


	I.  Facts Alleged

	1) On or about May 1, 1995
	"CD", (Connie Davis), "JS", (Jane Savastano) and at least one
	other party at SFI in Paramus arranged to have Plaintiff
	Bellamente examined by both Drs. Wagle and Fremed, and on or
	about June 8, 1995 letters demanding IMEs with these physicians
	of Plaintiff Bellamente were sent, with bcc notes to physicians
	indicating what was wanted of them.  Medical reports sent were
	marked before being sent.

	2) On July 25, 1995
	At the request of Jane Savastano, claims specialist for SFI,
	Dr. Fremed conducted an IME of Plaintiff Bellamente of
	approximately fifteen (15) minutes in duration for Defendant
	SFI, upon which he wrote a report of 4, single spaced, small
	type pages, and sent this report to Ms. Savastano dated
	July 25, 1995; Veronica Wade of SFI sent this report along
	with a denial of all neurological benefits to Mr. Bellamente,
	on September 15, 1995, almost two months after the report
	was received by SFI.  It is stamped as received by SFI July 31,
	1995.  Dr. Fremed's report is specified:

		OUR FILE # 29855
		YOUR CLAIM # 30-3204-312
		D/A: 09/16/94

	NB: Bellamente's cervical surgery had since been scheduled.

	3) On January 5, 1999
	Dr. Fremed issued "a paper review" of Plaintiff Bellamente's medical
	records.  Since this report was addressed to Michelle Wall of Melli,
	it can be assumed that it was she who hired Fremed.  This report
	was for use in the New Jersey actions for performance.

	4) On June 14, 1999
	Dr. Fremed issued "a paper review" of Plaintiff Bellamente's medical
	records.  Since this report was addressed to Michelle Wall of Melli,
	it can be assumed that it was she who hired Fremed.  This report
	was for use in the New Jersey actions for performance.
	Specified:
		OUR FILE # 29855
		YOUR FILE #16,809/15,810/17,994
		(Bellamente/Hammel vs. State Farm)
		D/A: 09/16/94

	5) On June 30, 1999
	Dr. Fremed issued "a paper review" of Plaintiff Hammel's medical
	records.  Since this report was addressed to Michelle Wall of Melli,
	it can be assumed that it was she who hired Fremed.  This report
	was for use in the New Jersey actions for performance.
	Specified:
		OUR FILE # 29855
		YOUR FILE #16,809/15,810/17,994
		(Bellamente vs. State Farm - UIM)
		D/A: 09/16/94

	6) Then on December 23, 1999, Dr. Fremed issued yet a
	   third paper review, again upon request of Michelle Wall
	   of Plaintiff Bellamente's medical records.
	   Specified:
		OUR FILE # 29855
		YOUR FILE #17,994
		(Bellamente vs. State Farm - UIM)
		D/A: 09/16/94

	Plaintiff Hammel has dissected Dr. Fremed's review of paragraph
	5) above in detail, showing the particulars of intentional
	misrepresentations of that review, while also exhibiting the
	techniques of the fraud, and the trickery and deceit attempting
	to hide those techniques and how they are used repeatedly.



	In the report, Dr. Fremed fails to mention that he has "reviewed"
	the complaint that Hammel wrote to New Jersey DOI on December 04,
	1995 on behalf of Bellamente [Exhibit B], in which Dr. Fremed's
	IME report was described as "cursory and amateurish", "rife with
	farce and folly", "cannot, therefore, in any way, be compared with
	the completely scientific and thoroughly professional examinations
	of Drs. Adams, Jotkowitz, Pojedinec and Rubin".  In Hammel's
	complaint to the New Jersey DOI, he also says,

		"What is also clear is that the very cursory nature
		of Dr. Fremed's examination and his disrespectful report,
		has done and continues to do physical, emotional, mental
		and financial damage to Mr. Bellamente but has also
		certainly, at very least, has ingratiated Dr. Fremed
		to State Farm."

	Plaintiffs now maintain that, Dr. Fremed's patent viciousness
	in the report of paragraph 5) above is explained by his additional
	fraud of not disclosing the source of his own incompetence to
	write an unbiased review of Hammel's medical records.

	Dr. Fremed thereby colors all of his IME report and his paper
	reviews with reckless and harmful fraud, deceit and trickery in an 
	attempt to hide that fraud, that can, in fact, be found therein.

	Plaintiffs include here by reference all of the paragraphs
	of the accompanying memorandum on the view of paragraph 5)
	above entitled:

	MEMORANDUM ANALYSIS, ON THE FACE OF IT, OF A REVIEW OF
	        PLAINTIFF HAMMEL'S MEDICAL RECORDS BY
	         ERIC L. FREMED, M.D., DATED 06/30/99

	where this purported review is dissected on the basis of
	documentation, reason, and medical and scientific reality
	and shown to be a sham, willfully fabricated in conspiracy with SFI
	and its attorneys, Melli, Guerin & Wright for the purpose
	of attempting to establish that no permanent physical injuries
	of Plaintiff Hammel are a consequence of the MVA of September
	16, 1994.  Although Plaintiffs will allege as violations of the 
	predicate acts of RICO in the acts surrounding the production
	of this sham, they happen to agree with Dr. Fremed's final
	conclusions referring to the accident of September 16, 1994,
	that "Dr. Hammel suffered no permanent neurologic injuries as
	a result of the accident in question.", and "Mr. Bellamente
	suffered no permanent neurologic injuries as a result of the
	accident in question.".

	The Permanent injuries of all kinds sustained by both Plaintiffs
	are a direct result of the patterns of racketeering activities
	complained of in this action, in which Dr. Fremed himself was
	a very active and willing participant.


	II. Conspiracies and Conclusions

	Dr. Fremed in conspiracy with SFI, its employee Idiana Murray,
	and SFI's attorneys, Melli Guerin & Wright, has produced five (5)
	documents of purportedly expert nature to deny Plaintiffs'
	meritorious claims on their insurance policy.

	In all five written purportedly professional documents, which
	have been subitted to an adjudicating body of arbitration,
	Dr. Fremed has come to a resoundingly absolute conclusion 
	that is beneficial and profitable to Defendant SFI, while
	disagreeing with every single one of Plaintiffs' treating
	physicians, most of whom don't even know of each other, and
	who are thus truly independent.

	In Dr. Fremed's excessive "reviews" of Plaintiff Bellamente's
	medical reports, referring to to documents and MRIs that do not,
	in fact, exist he also probes pre-existing conditions for which
	either SFM or SFI is also responsible, and which
	responsibilities he continues, fraudulently, to deny.

	Dr. Fremed, in his reviews of Plaintiff Bellamente's medical
	reports from the 1992 MVA, concludes that major injuries stem
	from that MVA and not from the MVA of 1994.  What Dr. Fremed
	fails to acknowledge is that injuries such as concussion as in
	any closed head injury, are well known to be cumulative.

	Dr. Fremed fails, utterly and totally, to acknowledge anything
	that is not expedient to the profit of SFI and of himself.
	Around his continuing sequence of his IME report of 1995 and
	each of his paper reviews of 1999, revolves a nexus of violations
	of predicate acts of RICO, in furtherance of the larger scheme
	designed by SFI in consort with SFM to defraud, rob and extort
	Plaintiffs, and in so doing has damaged them both greivously.


	Respectfully Submitted:


        William C. Hammel                     Alan J. Bellamente
        A-11 Moose Branch Road,               A-11 Moose Branch Road,
	Sweetwater Apartments 1A,             Sweetwater Apartments 8A,
        Robbinsville, NC 28771                Robbinsville, NC 28771
        (828) 479-1547                        (828) 479-1547

                     /S/                                 /S/
        -------------------------------      ------------------------------
        William C. Hammel                     Alan J. Bellamente

        DATE: February 4, 2000                DATE: February 4, 2000


	_______________________________________________________________



				EXHIBITS FOR

	Memorandum Concerning an IME Report and Various Paper Reviews
	by Defendant Eric L. Fremed, M.D., on the Medical Reports by
	Physicians Treating both Plaintiffs.



	1) On July 25, 1995  IME report on Plaintiff Bellamente

	2) On January 5, 1999 Paper Review of Plaintiff Bellamente's
	   medical records.

	3) On June 14, 1999  Paper Review of Plaintiff Bellamente's medical
	   records.

	4) On June 30, 1999  Paper Review of Plaintiff Hammel's medical
	   records, which is the subject of the following Memorandum
	   Analasis of A Medical Paper Review By Defendant Eric L.
	   Fremed, M.D., on Plaintiff Hammel's Medical Records.

	5) December 23, 1999, Paper Review of Plaintiff
	   Bellamente's medical records.


	_______________________________________________________________