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

	In the Matter of
        ____________________________________________
                                                   |
             WILLIAM C. HAMMEL,                    |
             ALAN J. BELLAMENTE,                   |
             et al.,                               |      AFFIRMATION OF
                                                   |
                  Plaintiffs                       |      WILLIAM C. HAMMEL
                                                   |
                   vs.                             |
                                                   |      No. 2:99:CV-44-T
             STATE FARM MUTUAL AUTOMOBILE          |
             INSURANCE CO.,                        |
             STATE FARM INDEMNITY COMPANY,         |
             et al.                                |
                                                   |
                  Defendants                       |
        ___________________________________________|

	AFFIRMATION OF WILLIAM C. HAMMEL


	William C. Hammel, being duly sworn, declares and deposes:


	1. I am an adult over the age of 18, and am a party to this
	   action.  I have personal knowledge of all of the following
	   and if called upon to testify upon the truth of thereof
	   I will.

	2. I was born on December 4, 1944 in New York City.

	3. According to family mythology, I spoke and read at a
	   very early age.

	4. By the age of eight years, which I do remember, I had an
	   English vocabulary beyond the average adult of my
	   milieu.

	5. About that time, I discovered music and studied piano.

	6. Later, having studied musical composition with men
	   whom the musical world considers brilliant, Stefan Wolpe
	   and Raoul Pleskow, I had become an accomplished composer,
	   respected by both men, had my music performed, commissioned,
	   broadcast and recorded.  On September 16, 1994, I was still
	   a member of the American Society of Authors, Composers and
	   Publishers (ASCAP).

	7. Since my dealings with State Farm Indemnity Co. over the
	   MVA of September 16, 1994, I have no idea whether I am still
	   a member of ASCAP.

	8. As a young teenager I discovered medicine as an area of
	   scientific study that I could understand grossly since
	   it did not require the mathematical skills of deeper
	   sciences.  My love of it as a science constantly showing
	   more and more connections between that which was previously
	   thought separate has continued to this day, even though my
	   academic work eventually took me through other paths than
	   being a physician.

	9. At the same time that I discovered medicine, I discovered
	   astronomy which I also studied by myself.  My parents,
	   fortunately, were indulgent in buying books for me.  I still
	   have the telescope bought for me in my teenage independent
	   study of astronomy, of astrophotography and the chemistry
	   of photography and optics.

       10. During those years, I discovered, by attempts at lens grinding,
	   that my talents were not very good at being an optician,
	   nor was I a very good carpenter, nor did I have a good singing
	   voice, and that, generally, talents have limits.

       11. During those years also, I was exposed to and lived in a
	   community where it was usual for anyone to speak as many
	   as six languages, and so developed an ear, assisted through
	   music, and a love of languages, particularly as they never
	   seem to translate one to another properly.  That, later
	   resulted in my, again independent, study of linguistics,
	   subsequently connecting that with the theory of formal
	   languages, computer languages, music and mathematics.

       12. During my High School years, since it was not available
	   as taught language, I learned Russian independently,
	   while formally learning Spanish and German.

       13. During my High School years, in my sophomore year, I
	   was finally introduced to real mathematics in Euclidean
	   Plane Geometry.  It was at that time my great love.
	   With that small mental explosion, I became interested
	   in how my particular mind worked, and so began a study
	   of psychology and eventually psychiatry.  I know now a
	   good deal about how my mind works, what it can do and what
	   is not within my abilities, and have no intention of
	   attempting to explain that here, as I still have much
	   to learn.

       14. In my college years I majored in first physics, but
	   discovered that as I was simply not good at carpentry
	   or lense grinding, I was also not good in a laboratory.
	   Since I had also exhausted the undergraduate mathematics
	   courses, I switched majors in my Senior year and graduated
	   with a mathematics BA and minors in physics, philosophy,
	   comparative languages (since I had taken French, German
	   and Russian), and music.

       15. With the help of one of the younger professors of physics
	   I studied quantum theory as an undergraduate.

       16. As an undergraduate, I developed an extension of differential
	   calculus that was unknown to my professors and deemed useless.
	   Later, I found that a great mathematician, Bernhard Riemann,
	   had already done it in the 1850's, and to my chagrin, more
	   generally.  The paper was then apparently only available in
	   German.

       17. As an undergraduate, I settled on "my problem" in physics,
	   to which the rest of life would be devoted: the reconciliation
	   of quantum theory with general relativity.  It is
	   a great problem of physics that has existed since 1915,
	   and has still not been solved.

       18. As a Senior I took graduate courses in physics, mathematics

       19. I continued taking courses in these previous three subjects
	   while I earned an MS in mathematics.

       20. During my undergraduate and graduate studies, I worked to
	   pay my tuition.

       21. Thereafter, I chose to study for my PhD at the University
	   of Wisconsin, Milwaukee (UWM) (1986) since it was possible
	   there to specialize immediately in either experimental or
	   theoretical physics.  I took to theoretical physics, and
	   augmented my studies in the mathematics department.

       22. While at UWM, I was the first, and as far as I know only,
	   graduate student who was ever assigned to teach an upper
	   level undergraduate course on solid state physics, and
	   also given the full responsibility of teaching a large
	   lecture class on introductory physics.

       23. While at UWM, in consort with a then postdoctoral student,
	   Stephen A. Fulling, now, full professor of mathematics at
	   Texas A&M, we organized a "Lyceum on Mathematical Physics"
	   to try to create more of an interaction between the Depts.
	   of mathematics and physics.  Stephen gave the first lecture,
	   I gave the second.

       24. While at UWM, my studies ranged over all the theoretical
	   specialties of physics, culminating in a thesis that was
	   connected to "my problem" adopted long ago.  The formidable
	   mathematics belies its crudeness.  After that, I resolved
	   to look for other possibilities by seeking deeper into
	   the essentials of relativity and quantum theory.

       25. As a product of my thesis, three professional papers
	   were published, two in Il Nuovo Cimento, one in the
	   Journal of Mathematical Physics.

       26. My last years at UWM were paid for by a University
	   Scholarship, a decision of the graduate faculty of physics.

       27. Shortly after my PhD (1974), my mother died and left me enough
	   money to live pursuing my goals in music and science,
	   physics and mathematics in particular.  The conferral of a
	   PhD is not just another academic degree, though it is the
	   highest.  It is a judgement by a body of experts, the graduate
	   faculty, that the conferee knows the subject in which the degree
	   has been conferred, is capable of independent thought and study,
	   and that he has also made a significant contribution to
	   the field in question, thus demonstrating his independent
	   abilities.

       28. My mother's deeply disturbing death occurred while I was
	   visiting associate professor of physics at UW-Parkside.

       29. While in Milwaukee, several pieces of my music were
	   performed under the auspices of the Music Dept. of UWM
	   and Dr. John Downey of that department.

       30. While in Milwaukee, several pieces of my music were
	   performed by organist John Weissrock, and recorded on the
	   Outreach label.

       31. While in Milwaukee, I was commissioned by the Green Bay
	   Symphony Orchestra for the Bicentennial.  The commissioned
	   piece, a concerto for orchestra, was performed at the
	   orchestra's Bicentennial Concert.

       32. While living in Milwaukee, my "Variations for Strings
	   and Tympani" was premiered by the Dayton Symphony Orchestra,
	   and later broadcast.

       33. While in Milwaukee, I also studied Gross Anatomy and
	   and muscle physiology as a foundation for beginning a
	   weight training program, which continued with only minor
	   interruptions up to September 16, 1994.

       34. After moving to Teaneck New Jersey in 1979, I did some small
	   work with Prof. Yemini at Columbia on the statistical mechanics
	   of large computer networks.

       35. Shortly thereafter, I found myself doing research in Molecular
	   Biology at Columbia University with Prof. Cyrus Leventhal,
	   concerning the relationships between molecular geometry and
	   biological activity, leading to my interest in the fundamental
	   protein folding problem.

       36. The work in molecular biology was assisted by my previous
	   independent studies, but required a closer look and study
	   of biochemistry and the electrical properties of cell
	   membranes.  All of this connected with previous studies
	   of various branches of medicine.

       37. The work in molecular biology required learning the UNIX
	   operating system for computers, and then C language.

       38. Next door to the "theoretical molecular biology lab" were
	   people doing work in molecular neurology, which was, an
	   already fascinating interest, leading to discussion and
	   further study connected with the molecular biology projects
	   on which I was working.

       39. During my time working in molecular biology, I found that
	   my developed skills and knowledge in UNIX and C programming
	   were valuable, and I took advantage of that, as a way of
	   earning money so that I might have more time to
	   continue working on my research in theoretical physics,
	   and musical composition, activities which had never ceased
	   since their inception.

       40. I worked as a computer consultant, teaching public and private
	   courses on UNIX and C, one, a full week course at the FCC in
	   Washington D.C. on UNIX.

       41. At about this time my neighbor Mr. Martin Kalman, an attorney
	   in personal injury law, asked me if I could develop a computer
	   system for a case database from which legal documents could be
	   produced.  I said yes, and spent three years designing and
	   and coding the 40,000 lines of code for that.  To my knowledge
	   that system is still functioning in the offices of two 
	   New York law firms.  My long time friend and business
	   associate Alan Bellamente was associated with this enterprise.

       42. Years later Mr. Bellamente became interested in the video
	   retail business, and asked me if I would be interested in
	   joining him and another associate in the business.  I said
	   yes, and I wrote and maintained the software for that business.

       43. At the time of 1994 MVA, I owned this business as a d/b/a,
	   did consulting and maintainence of my commercial programs
	   under Lex*Data, was making considerable progress with my
	   physics research, composing music, practicing piano, and
           maintaining an exercise program of weight training and
	   cardiovascular work, while still keeping up with developments
	   in all my other accumulated fields of mathematics molecular
	   biology, computer science, medicine, astrophysics and
	   linguistics.

       44. Now, all of that is gone.  The continuity of
	   of knowledge acquisition has been irreparably broken, my
	   once muscular body has become mass of atrophied muscles,
	   that spasm at the slightest overuse, leaving me completely
	   unable to care for myself, unable to return to any of my
	   prior activities and unable to be productive in any way
	   without considerable help from others.

       45. I know enough about the specifics of my condition to say
	   three things: (1) given the proper help and environment,
	   which due to its expense, is beyond what can be available
	   to me, I can regain some of the muscular strength that
	   has been lost. (2) the unbearable pain that can be made
	   bearable through medications and other facilities which
	   are economically unavailable, will never get any better.
	   (3) Without the proper help and environment, my body and
	   mind will continue it's steady and rapid decline to the
	   point of death from some secondary cause.



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

	_______________________________________________________________