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

        ____________________________________________
                                                   |
             WILLIAM C. HAMMEL,                    |
             ALAN J. BELLAMENTE,                   |
             et al.,                               |      MEMORANDUM ON
                                                   |  THE RACKETEERING NATURE
                  Plaintiffs                       |   OF THE MISCONDUCT OF
                                                   |     STATE FARM MUTUAL
                   vs.                             |   AUTOMOBILE INSURANCE
                                                   |          COMPANY
             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 ON THE RACKETEERING NATURE OF THE MISCONDUCT OF
	      STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY



	In Campbell v. State Farm Mutual Automobile Insurance Co.,
	No. 890905231, slip op. at 53 (Third Judicial Dist., Salt Lake
	City, Utah, Aug. 3, 1998), a third party action on grounds of
	Bad Faith, the Court found ample evidence for State Farm's
	misconduct. (See the decision attached as Exhibit 1)

	Plaintiffs quote extensively from the Court's opinion, written
	by The Honorable William B. Bohling, since it supports
	Plaintiffs' allegations of extensive and wide ranging patterns
	of racketeering involving multiple schemes of fraud, extortion
	robbery committed through various media including wire and
	mail, and clear conspiracy to commit these offenses; and that
	these offenses extend from the claim-handling process into
	the very litigation process itself, not only systematically
	devastating the very policyholders to whom it has a fiduciary
	duty, but also using, abusing and burdening the Courts with its
	intolerable racketeering schemes.

	The very same unlawful tactics and schemes upon which Plaintiffs
	complain in their amended complaint are asserted in the Court's
	opinion as being of a general nature regarding State Farms's
	"business practices"; they fulfill the criteria for a pattern
	of racketeering activities as defined in 18 USC 1961(1).

	Plaintiffs remark that though this be a "mere" bad faith action,
	it is one of the most egregious examples of such an allegation,
	and one, such an extraordinary amount of evidence and testimony
	has been brought to bear on the defendant State Farm Mutual
	Automobile Insurance Co. (SFM), that it is likely that Plaintiffs
	contemplated the legal theory of Federal RICO from the outset,
	but were intimidated by the as yet nonexistent decision of the
	US Supreme Court on Humana v. Forsyth.

	In the Court's opinion Id., at paragraph 29

		    The Nature of State Farm's Misconduct

	[Id. paragraph 29]
	"The second Crookston factor, which mirrors the BMW v. Gore
	'reprehensibility' factor, likewise strongly supports the
	punitive damages awarded by the jury.  Whether a defendant's
	misconduct is of a reprehensible nature is '[p]erhaps the
	most important indicium of the reasonableness of a punitive
	damages award.' Gore, 116s. ct. at 1599.  The U. S. Supreme
	Court has singled out for special condemnation schemes of
	'trickery and deceit,' especially when they target people
	who are 'financially vulnerable' and involve 'repeated
	misconduct.' Id.  Further, the Court has identified as
	particularly reprehensible a defendant's use of 'deliberate
	false statements, acts of affirmative misconduct, or
	concealment of evidence of improper motive.' Id. at 1601."
   
	[Id. paragraph 31]
	"i) State Farm's policy of using its auto insurance claim-
	    handling process as a profit center by offering its claims
	    adjusters undisclosed incentives to wrongfully deny benefits
	    owed consumers.

	The records contains a large body of evidence, in the form of
	State Farm's own internal corporate documents, the testimony of
	its current and former employees, and credible expert testimony,
	that over a period of approximately two decades, State Farm has
	pursued an official policy of using it auto insurance claim-
	handling process as a profit center, by systematically providing
	its claim adjusters with unlawful incentives to wrongfully deny
	benefits owed consumers."

	[Id. paragraph 34]
	"The record contains extensive evidence that for approximately
	two decades, State Farm has disregarded well-accepted industry
	rules by turning its claims-adjusting process into a profit center,
	to the point of giving its adjusters specific numerical targets
	with regard to average payouts per claim. Meeting these targets
	leads to better pay and promotional prospects; missing them leads
	to criticism, retarded prospects at the company and, ultimately
	a threat to one's continued employment. "
   
	[Id. paragraph 47]
	"State Farm's use of unlawful and unethical means to conceal its
	profit scheme and evade punishment for it.
   
	"The record also contains ample evidence, that throughout at
	least the past two decades, State Farm has resorted to a variety
	of wrongful means to attempt to evade detection of and liability
	for, its unlawful profit scheme. Using these tactics State Farm
	has managed to construct a nearly impenetrable wall of defense
	against punishment for its wrongdoing, so effective that it is
	able to pressure its adjusters to deny consumers insurance
	benefits with impunity, knowing:

		1) that few of its victims will even realize they have
		   been wronged.

		2) that fewer still will be able to sue

		3) that only a small fraction of those who do sue will
		   be able to weather the years of litigation needed to
		   reach trial

		4) that any victims who actually reach trial will have
		   great difficulty establishing the basis for punitive
		   damages when met with claims that only an 'honest
		   mistake' was made, supported by a body of evidence
		   that has been systematically sanitized, padded,
		   purged, concealed, destroyed or rehearsed."
   
	i) State Farm's official policy of giving its adjusters
	   undisclosed incentives to deny customers benefits owed them,
	   in order to enhance corporate profits by wrongfully turning
	   its claim-handling process into a profit center:

	[Id. paragraph 47]
	"ii) State Farm's use of various wrongful means to conceal this
	    profit scheme and evade punishment for it:"

	[Id. paragraph 48]
	"The record indicates that these evasion tactics are so
	successful that State Farm trains its employees to ignore the threat
	of punitive damages in making their claim-handling decisions. State
	Farm has relied on five principal evasion tactics, each of which is
	reprehensible."

		[Id. paragraph 49]
		a) Systematic targeting of vulnerable and defenseless
		   consumers.

		[Id. paragraph 50]
		b) Systematic destruction of documents, requested in
		   litigation, that reveal the profit scheme.

		[Id. paragraph 58]
		c) Systematic manipulation of individual claim files
		   to conceal claim mishandling

		[Id. paragraph 60]
		d) Systematic manipulation of testimony by employees

		[Id. paragraph 61]
		e) Systematic efforts to intimidate opposing claimants,
		   witnesses and attorneys.

	More specifically at the above cited paragraphs:
   
	[Id. paragraph 49]
	"a) Systematic Targeting of vulnerable and defenseless consumers"

	"The record clearly supports the conclusion that State Farm's
	undisclosed policy of using its claims handling process as a profit
	center to systematically deny benefits owed to consumers is
	deliberately crafted to prey on "the weakest of the herd" -- the
	elderly, the poor, and other consumers who are least knowledgeable
	about their rights and thus most vulnerable to trickery or deceit,
	or who have little money and hence have no real alternative but to
	accept an inadequate offer to settle a claim at much less than fair
	value. The testimony from Ray Summers, Bruce Davis and Ina DeLong
	on how they were trained to target such consumers, and the expert
	testimony from Gary Fye, covering the various tactics predicated
	in this philosophy and the internal company documents demonstrating
	this philosophy in action, was especially significant."

	[Id. paragraph 50]
	"b) Systematic destruction of documents, requested in
	   litigation, that reveal the profit scheme.

	"The record contains consierable evidence concerning State
	Farm's aggressive efforts to 'manage' documents that might
	damage it in gad-faith litigation, including evidence of
	extensive efforts to erase large portions of the corporate
	memory. [...] the evidence of State Farm's systematic and
	long-running efforts to destroy internal company documents
	revealing its profit scheme supports an inference that State
	Farm was seeking to minimize the possibility that it would be
	punished for its underlying misconduct."

	[Id. paragraph 58]
	"c) Systematic manipulation of individual claim files
	   to conceal claim mishandling

	"The record also contains ample evidence that State Farm
	has long directed its claim adjusters to systematically
	'sanitize' or otherwise manipulate individual claim files
	to provide a false, innocent picture of how the claim was
	handled, in an effort to minimize exposure to later law
	suits alleging bad-faith claim handling."

	[Id. paragraph 60]
	"d) Systematic manipulation of testimony by employees

	"The record contains substantial evidence that State Farm
	has long had a corporate policy, in defending against cases
	alleging bad-faith claim handling, of aggressively 'coaching'
	its employees to ensure that their testimony will be favorable
	to the company and that opposing attorneys will be hindered in
	their ability to obtain relevant, non-privileged information
	from such witnesses. [...]  The supervisors were taught that
	in Courtrooms, 'truth is illusory' how, through extensive
	coaching, a memory can be 'created' for a company witness;
	and how, by repeating questions and prepared answers 'numerous
	times,' State Farm attorneys and witnesses can work together
	to 'totally frustrate' the efforts of opposing attorneys."
	

	[Id. paragraph 61]
	"e) Systematic efforts to intimidate opposing claimants,
	    witnesses and attorneys"

	"Finally, the evidence in this case supports the conclusion that
	State Farm has a regular practice of working to wear down and outlast
	plaintiffs and opposing attorneys in lawsuits seeking to punish it
	for bad faith claim handling, by using a variety of tactics to
	intimidate claimants, witnesses and attorneys who oppose it.
   
	[Id. paragraph 62]
	" [...] Adjuster Ray Summers testified that a common tactic
	of State Farm was that of 'unjustly attacking the character,
	reputation and credibility of a claimant and making notions
	to that effect in the claim file to create prejudice in the
	event the claim ever came before a jury.'"

	[Id. paragraph 65]
	"Finally, with respect to intimidation of attorneys who might
	be in a position to bring contingent-fee litigation against
	State Farm on behalf of victims who have few resources, the
	record reveals that Sate Farm has a practice of resorting to
	what one of its consultants (as part of the official training
	process) approvingly referred to as 'mad dog defense tactics'.
	At a national conference, approximately 200 of State Farm's
	divisional claims superintendents were instructed that 'we
	keep plaintiffs tied up in law and motion for months.  Now
	that's the old mad dog defense tactic, but it works.'
	17 Tr. 205.  Expert witness Steve Praeter testified to State
	Farm's methods for exploiting its superior resources to wear
	out opposing attorneys with unending, vexatious and expensive
	litigation tactics.  According to Praeter, State Farm focuses
	on making the litigation process as time consuming, expensive
	and prolonged as possible by, for example, making meritless
	objections; claiming false privileges; and destroying documents
	or claiming that they don't exist or would be too expensive
	to retrieve.  17 Tr. 163-164, 168-74. [...]  Gary Fye also
	provided expert testimony on these 'mad dog' litigation
	tactics, concluding that State Farms's use of them is
	'extremely profitable.' even in light of the cost involved
	in an individual case, because of their in terrorem value
	across a wide range of cases in intimidating claimants and
	attorneys into not filing law suits at all, or settling claims
	for small amounts of money rather than endure the financial
	drain of litigation in face of such abusive tactics."

	[Id. paragraph 80]
	"The evidence on the scale of fraud, and the need for devastating
	punishment, is far more extensive in this case than in
	Crookston.  State Farm has sold as its product 'peace of mind.'
	using an advertising slogan which promises that consumers can
	count on it to act 'like a good neighbor.'  But as the trial
	proceeded, it became a matter of plain evidence that State
	Farm's corporate policies involve betraying the trust that it
	invites its policyholders to place in it, the trust it has a
	fiduciary duty to uphold.  The jury could easily find from the
	evidence that State Farm's claim-handling practices are
	predicated on exploiting the trust placed in it by its
	policyholders, and the Court so finds in making its own analysis
	of the proper amount of punitive damages in this case.  In
	sum, in light all the above considerations and the other points
	made by the Campbells in their memoranda and oral argument,
	the reprehensibility of State Farm's policies and practices,
	both generally and as they were applied to the Campbells,
	strongly supports a jury award of massive punitive damages."

	The Court thus found ample evidence of systematic fraud,
	conspiracy to commit fraud, extortion and conspiracy to
	commit extortion, robbery as defined in Hobbs, and conspiracy
	to commit robbery, and thus significant and pervasive
	patterns of racketeering activities under USC 18 1962(a),
	where the enterprise and the person is defined as SFM.

	Judge Bohling states further regarding the number of victims
	involved, an affect on interstate commerce, multiplicities
	of schemes, as well as a threat of continuation into the future.

	[Id. paragraph 82]
	"It appears to the Court that under State Farm's scheme, a
	considerable percentage of policyholders is victimized by a wrongful
	denial of benefits, oftentimes when these policyholders are the most
	vulnerable. And it certainly appears to the Court that State Farm
	pursues an official policy established to encourage such wrongful
	denial of benefits where State Farm believes it can successfully be
	accomplished."
   
	[Id. paragraph 83]
	"Another effect of State Farm's policies is that it puts auto
	insurance companies who play by the rules at a competitive
	disadvantage, allowing State Farm to increase its market share
	or its profits (whichever it is putting the emphasis on) or a
	combination of both, by having an advantage that honest companies
	don't have: the shortchanging of policyholders on claim amounts
	that should be paid.  As the Campbells demonstrated with expert
	testimony, this inevitably creates pressure on the honest companies
	to resort to the same sort of misconduct in an attempt to stay even
	with State Farm, extending the damage to consumers through out the
	auto insurance marketplace as a whole."

	[Id. paragraph 84]
	"e. Probability of Future Recurrence of State Farm's
	    Misconduct"

	"The Court has already found that State Farm has carried out
	a persistent scheme of wrongful conduct.  It appear to have
	been extremely profitable, as the Campbells' experts on the
	insurance industry testified, and as various examples of the
	scheme in practice strongly support.  Further, despite
	testimony from State Farm witnesses that the improper payout
	goals at the core of the scheme was assertedly 'obsoleted'
	in 1992 (and again in 1994), the Campbells presented ample
	evidence that this incentive system (including its improper
	goals) - the engine that pressures adjusters to wrongfully
	deny benefits to consumers on a wide range of claims - remains
	in operation today.  Only the documentation has changed, for
	appearances sake: as the Campbells proved with internal
	company documents and through testimony of knowledgeable
	witnesses. [T]he scheme is now carried out verbally, to
	avoid the creation of documents that might be damaging to
	the company in litigation.

	[Id. paragraph 98]
	"Certainly, the Court does not believe that statutory and
	regulatory sanctions that could be brought against State
	Farm under Utah law are minimal, nor does the fact that
	these sanctions have not to date been pursued by the regulatory
	and prosecutorial authorities support the claim that the
	remitted amount of punitive damages is excessive.  State
	Farm places considerable emphasis on the argument that the
	analysis should concern not the civil and criminal penalties
	that it could be subjected to under existing Utah law,
	but instead what penalties are likely as a practical matter,
	given past enforcement practices. [...]  If anything, the
	absence of any such aid from these authorities is a basis
	for enlarging the permissible punitive damages because of
	the seriousness and difficulty of parties such as the
	Campbells and their counsel, unassisted, taking a case of
	this nature all the way to trial.  It requires the will of
	David against a Goliath, or of a Rocky Balboa against an
	Apollo Creed, to stay the course and bring litigation such
	as this to the point where it rests today."

	THEREFORE, the Campbell Court has found that State Farm,
	has been engaged, for over twenty years, in a systematic
	defrauding of its policy holders, and in doing so it has
	thus systematically committed the predicate acts of RICO.
	In sequence of occurrence:
	
		1) CONSPIRACY TO COMMIT FRAUD: by conspiring of many
		   within the company to agree to sell insurance
		   policies, knowing very well that the policies were
		   not going to be honored,

		2) FRAUD: by selling insurance policies, knowing very
		   well that the policies were not going to be honored,
		   when policyholders relied upon them to their
		   detriment.

		3) CONSPIRACY TO COMMIT ROBBERY: by conspiring of many
		   within the company to deny meritorious claims.

		4) ROBBERY: by denying a policyholder's benefits that
		   should rightfully be theirs, without their consent.

		5) CONSPIRACY TO COMMIT ROBBERY: by conspiring of many
		   within the company to send claimants with personal
		   injuries to physicians known to return reports in an
		   allegedly IME, falsely supporting the scheme of
		   fraudulent denials of benefits.

		6) CONSPIRACY TO CONSPIRE TO COMMIT FRAUD, ROBBERY
		   AND EXTORTION: by conspiring of many within the company
		   enlist the aid of physicians in perpetrating the schemes
		   fraud, robbery and extortion by sending claimants with
		   personal injuries to these very physicians.

		7) FRAUD: by purporting to a claimant that the IME is what
		   it's name is: the predicate upon which the policy
		   holder relies to his detriment, comitted through mail
                   and wire.

		8) EXTORTION: by sending the "IME request letter", that
		   usually threatens that benefits may be terminated for
		   noncompliance.

		9) EXTORTION: by consistent continuation of the scheme
		   in which 1-8 above are embedded so that the claimant is
		   forced into litigation, thereby keeping for themselves
		   interest, income and use of money that rightfully
		   belongs to the claimant.


	Thus, all the elements of RICO are clear in the Campbell
	Court's findings, including an affect on interstate commerce,
	a large nexus of predicate acts, a continuity which is still
	open, similar tactics, methods and victims, a large number of
	victims as well as a threat of continuation and a large potential
	number of victims.  There is an overall purpose of unjust profit
	and enrichment, and indeed a large nexus of multiple schemes
	in addition.

	Again, in  Robinson v. State Farm Mut. Auto. Ins. Co.;
	No. CV-OC-9498099-D (4th jud. dist. ct. Ada County Idaho),
	a more recent case, the national scheme has been revealed
	once more In his memorandum decision of August 6, 1998,
	District Judge D. Duff McKee, found that the State Farm claims
	representative in that case had treated the first party claim
	for medical payments benefits as an "adverse claim" rather
	than a first party claim and that the utilization review was
	"a completely bogus operation," that prepared "cookie cutter"
	reports of stock phrases, assembled on a computer, supporting
	the denial of claims by insurance companies." (Op. pp. 3-5)

	The Court went on to find:

		"The inferences from the evidence were inescapable
		that the claims examiner in this case did not use
		the paper review process and referral to the captive
		physician with any intent of obtaining an independent,
		objective review of the Plaintiff's medical
		circumstance.  Rather, he did so with the expectation
		that the reports issued would support his denial of
		the claim.  The evidence was further clear that the
		procedures which enabled the claims examiner to utilize
		these slanted and biased reviews and examinations were
		set up by State Farm management, included in the
		training given to the claims examiner, and encouraged
		by management as cost cutting devices."

		"Competent evidence was offered that State Farm
		management was aware of the tainted reports being
		generated by the paper review organizations and use of
		captive physicians for independent medical examinations,
		but was deliberately indifferent to the deficiencies
		because the reports were leading to reduced claim
		expenses.  The evidence was sufficient to support the
		conclusion that the decision to delay and stall the
		medical claims of Robinson was not based on a fair
		debate.  The only debate that existed was the debate
		engineered by the claims examiner, predicated on his
		unfounded intuition and supported only by the phony
		reports from the paper review organization and the
		scripted advice of the captive doctor.  The insurance
		company cannot create a dispute against the claim out
		of thin air, and then claim that it is entitled to
		debate the dispute it created as a defense to its
		delay in evaluating and paying the amounts justly due."

		"The proof indicated that the phony processes and
		improper claims handling procedures by the lying
		adjuster in this case permeated from the local office
		to regional management, and that the procedures enabling
		the use of paper review companies with the expectation
		of false and misleading reports permeated to the very
		top level of State Farm at the national level."
		(Op. pp. 6-7).

	The Court went on to find, specifically, that culpability
	went from the individual claims representative to the highest
	levels of management:

		"I find that evidence was clear and overwhelming that
		State Farm, beginning with its claims adjuster and
		running up through its management, participated in the
		egregious process of manufacturing factitious reports
		and obtaining biased opinions under the guise of
		obtaining independent and objective medical reviews.
		State Farm knew these evaluation processes were tainted
		and not objective.  The only conclusion to be drawn from
		this was that State Farm intended by these processes to
		reduce the amount of money it would have to pay on
		legitimate claims submitted by its insured."
		(Op. p. 16).


	In the more recent case of Avery v. State Farm Mutual
	Automobile Insurance Company,(Circuit Court, 1st Judicial
	Circuit, Williamson County, Illinois (Case No. 97-L-114),
	involving State Farm's use of after-market parts in the
	repair of vehicles, the Illinois trial court stated, after
	an independent consideration of the evidence:

		"The Court finds that State Farm, in light of its
		knowledge of the inferiority of the non-OEM
		'crash parts', misrepresented, concealed, suppressed,
		or omitted material facts concerning the non-OEM
		'crash parts' with the intent that its policyholders
		rely upon these deceptions..." (See, copy of Judge
		John Speroni's Judgment, attached as Exhibit 2, as well
		as verbatim transcripts of evidence presented in that
		as Exhibits 3-9)

	The trial court went on to find that punitive damages were
	appropriate and awarded $600,000,000.00 in punitive damages
	against State Farm.

	In addition to these predicate acts of RICO, there is systematic
	Breach of Contract as well as Breach of Fiduciary Duty, as well,
	of course, Bad Faith in State Farm's wholesale abuse of its policy
	holders, and those third parties to whom it owes still a fidiciary
	duty.


	Then in the litigation process itself through which fiduciary duty
	is still owed,  State Farm, again, systematically continues to
	breach that duty, engages in regular abuses of discovery,
	through its captive and suborned attoneys and in so doing also
	denies its claimants due process, and also in so doing, harms all
	citizens of U. S., all States and their economies in which it is
	permitted to do business,  The U. S. Federal government, the
	U. S. as a whole, and burdens and abuses the Courts of The
	United States, at all levels with its intransigent patterns
	of racketeering activities.

	Other cases that amplify and reinforce the picture of State
	Farm Mutual Automobile Company presented here are:

	   Middler v. State Farm, Superior Ct. Calif. County of
	   Los Angelos, NW Dist. No. LC021140

	   State Farm Fire & Cas. Co. v. Suprior Court (Taylor),
	   No. B106120 (Cal. Ct. App. Apr. 22, 1997)

	   Betty Olson v. State Farm Mut. Auto. Ins. Co.;
	   No. CIV 96-06105 (Ariz. Sup. Ct.)


	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



	_______________________________________________________________


	
	      MEMORANDUM ON THE RACKETEERING NATURE OF STATE FARM
	                 AUTOMOBILE INSURANCE COMPANY

	                         EXHIBIT LIST

	
	1. Campbell v. State Farm Mutual Automobile Insurance Co.,
	   No. 890905231, slip op. at 53 (Third Judicial Dist., Salt Lake
	   City, Utah, Aug. 3, 1998).  Opinion of the Honorable
	   William B. Bohling.
	   [Available in PDF format at www.altmanonline.com]

	
	2. Avery v. State Farm Mutual Automobile Insurance Company,
	   (Circuit Court, 1st Judicial Circuit, Williamson County,
	   Illinois (Case No. 97-L-114). Opinion of the Honorable
	   John Speroni on counts II and III, verbatim copy. 

   
                   State Farm auto-parts trial documents
                                      
	The following memos are verbatim copies of State Farm's internal
	documents that were entered as evidence in the auto-parts class
	action lawsuit in Marion, Ill. On Oct. 4, a jury found State
	Farm guilty of breaching its contract with its policyholders and
	awarded $456 million to the plaintiffs. On Oct. 8, Judge John
	Speroni ordered State Farm to pay an additional $730 million in
	damages.  

	
	3. Memo from State Farm assistant vice president of auto
	   property claims Bill Hardt, stating that aftermarket parts
	   aren't the same as OEM parts.

	
	4. Internal State Farm memo from Samantha Bird to other State Farm
	   employees instructing them to "dump" their old documents.

	
	5. Memo from State Farm reinspection superintendent, Westlake
	   regional office, Stephen Booth, regarding the substandard
	   quality of aftermarket parts.

	
	6. Letter from State Farm claims vice president G. Robert Mecherle
	   to Pier Talenti of the Detroit Testing Laboratory, a reviewer
	   of aftermarket parts quality. Mecherle mentions that several
	   plants are producing substandard aftermarket parts.

	
	7. Rough draft of a memo from Ben Parr, State Farm's former senior
	   automobile industry liaison, to Jack Gillis, an executive at
	   the Certified Automotive Parts Association, regarding the
	   substandard quality of the manufacture of aftermarket parts.

	
	8. Part two of a rough draft of a memo from Ben Parr, State Farm's
	   former senior automobile industry liaison, to Jack Gillis,
	   an executive at the Certified Automotive Parts Association,
	   regarding the substandard quality of the manufacture of
	   aftermarket parts.

	
       	9. Personal notes from Certified Automotive Parts Association
	   executive director Jack Gillis from his trip to Taiwan. Gillis
	   notes that an OE factory makes CAPA parts look bad.

	
       10. The three Declarations of Amy Girod Zuniga.
	   (As verbatim transcripts)

	
       11. State Farm Agents who Care, as presented on their
	   Internet web pages (www.statefarmagentswhocare.com).



	_______________________________________________________________