It has been traditional RICO case law that that the statute says exactly and only what it says: that only damages of business and property are compensible under 18 USCA 1964(c), the civil cause of action.
We argue that damages should be considered, under RICO, more broadly under certain circumstances, and that these circumstances arise in our Amended Complaint.
To start at the beginning go the DIARY PAGE.
UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA BRYSON CITY DIVISION ____________________________________________ | WILLIAM C. HAMMEL, | ALAN J. BELLAMENTE, | et al., | MEMORANDUM ON | DAMAGES Plaintiffs | AND | CAUSALITY vs. | (Attachment 6) | 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 DAMAGES AND CAUSALITY Summary: Plaintiffs will argue, in nonexclusive alternatives: That real and permanent business and property damages were primary in this particular case; that consequential personal damages flowed proximately from these primary business damages; that damages to business were also personal damages in this case, and that personal and business damages need not be seen as one flowing from the other, but that they are simultaneous and and independent with intertwining consequences as time progresses; and that damages compensable under RICO in this particular case should not be solely restricted to those of business and property precisely because of the legally intertwined conditions of persons and businesses. Finally, Plaintiffs argue, generally, that although in SEDIMA, S.P.R.L. v. IMREX Co., 473 US 479 (1985), the court quietly accepts that only "business and property" are compensable under RICO, Justice Marshall, in his dissenting opinion actually gives reason to expand this restriction on damages, in some cases, rather than giving the reductio ad absurdum argument that he sought in order to contradict the majority opinion. Preliminaries: 18 Chap. 96 nowhere defines the meaning of of the word 'business', and there are several ways in which it can be construed. There are 'businesses' whose sole purpose is to make a profit, and from which an owner and/or employees derive income directly or indirectly by providing goods and/or services; there are not for profit businesses, 501(C)(3), which may not produce a profit; a "Subchapter S" corporation is expected to lose money in its infancy while it is being capitalized and building its power to produce income. The American College Encyclopedic Dictionary, Spencer Press (1953) gives as the first meaning, "one's occupation, profession or trade"; Webster's New Collegiate Dictionary (2d ed.) (1953) gives eight meanings, the first is obs. "busyness", the second gives "one's rightful work or personal concern", the third gives "one's particular, esp. one's regular work, occupation, or employment". Any specific involvement with commercial or economic matters appear at and below the sixth meaning. There is no specific requirement that one derives income from the activity or even nonactivity of one's business, although the possibility is inherent. The destruction of businesses that produce a product but do not produce income, is still an immediate injury to business even though one can also see consequent direct injury to future product or future income. Plaintiff Hammel had "businesses" that consisted of scientific research and artistic production, upon which he worked for over 20 years, yet that produce little or no income, around the time of the MVA, and also around the time of the injuries being discernable as having direct cause in the racketeering enterprises of the Defendants. These non-income producing businesses nevertheless had existence and production can be demonstrated. These too have sustained injures diretly caused, by Defedants' Racketeering activities, to be destroyed. Yet are they not businesses with future potential of income? I. A. HOW property and business suffered setbacks from the MVA: Initial consequences of the MVA are the issue of State suits in New Jersey. physical - DAMAGES (reversible) business | property - financial | - SETBACKS Initial damages caused physical, business and property SETBACKS that were recoverable, and physical DAMAGES, that were also correctable, recoverable, and reversible at the time of SFI's denials of all medical benefits, which benefits were reasonably expected by Plaintiffs. Plaintiffs do not claim these initial and reversible injuries, nor seek recompense for them. That is a matter for the Judicial System of New Jersey. Were it not for the activities of the enterprises, these damages and setbacks would have been mended so as not to have resulted in any significant discontinuity in either Plaintiff's life, and would not have left Plaintiffs with permanent and severe damages. This is what gives rise to Plaintiffs' Federal claims and the damages for which they seek recompense. Plaintiffs explain in more detail in the following subsections B and C. B. HISTORY and BACKGROUND Before the MVA of September 16, 1994: Plaintiff Bellamente had been recovering from a previous MVA of August 6, 1992, which occurred while he was insured by State Farm Mutual. During that recovery period, business setbacks resulted, no claims for which were made. Plaintiff Hammel had never been injured in any MVA, was active and athletic, and was completely asymptomatic regarding any alleged previous physical or emotional conditions that have ensued. Business setbacks of Plaintiffs' began with the decreased ability of both Plaintiffs to own, operate and maintain a retail video rental business, a computer consulting business, and a not uncomplicated conservatorship. After SFI's unlawful denials of medical benefits, Plaintiffs' time and energy, required to deal with unending patterns of racketeering tactics of SFI in denying claims and delaying their responses, precluded Plaintiffs' normal and usual operations of their businesses. By the time Plaintiffs understood the scheme of calculated fraud of SFI, their business setbacks, having been made so severe, found it financially impossible to seek the necessary medical treatment, except under the insurance benefits to which they were entitled. Though there were physical injuries from the MVA, as all Plaintiffs' treating physicians, as well as SFI's 3 IMEs by Dr. Linder, have affirmed, those were seemingly acute in nature, and occurring at the time of MVA. They are totally distinct from injuries claimed here, which were knowingly, and recklessly inflicted on Plaintiffs through the racketeering enterprises of the Defendants. The injury, to business and business property, being its complete loss, along with the loss of the ability "to do business" and "to work", meaning to work reliably in some way, did NOT flow from the MVA injuries, but rather exactly from the racketeering activities of the defendants, and their predicate acts, the purpose of which was to profit mutually, and to annihilate the insurance in fact, that plaintiffs had been paying for, and relied upon. When the inevitablitiy of loss of business and residence became clear in November 1995, the last desperate act was the writing of the complaints to The New Jersey Department of Insurance Department of Consumer Complaints. The amount of time and energy required to write those was enormous, all of which should have been spent on what was left of the video business. That practically removed Plaintiff Hammel from business activities. C. In 1988 Plaintiff Bellamente was appointed conservator for his elderly aunt Edna M. Clough, manged her care and investments, and continued as conservator until about March 1995, when he finally had to resign that appointment due to loss of his ability properly to manage his aunt's affairs. Plaintiff Bellamente's income from that source was then lost. As a result of a prior MVA in 1992, Plaintiff Bellamente's retail video rental businesses in Midland Park, New Jersey, and then in Rochelle Park, New Jersey, had to be closed, in 1993 and 1994 respectively. Those businesses were operated as Ultra Videos Inc., a corporation begun by Plaintiff Bellamente, et. al., in 1991. Plaintiff Hammel designed and wrote the computer software, installed and maintained all hardware used to operate the businesses, and was an officer in Ultra Videos Inc. On August 6, 1993, a retail video rental business was opened by both Plaintiffs, in Ridgefield Park, New Jersey with Plaintiff Bellamente as a d/b/a. As Plaintiff Bellamente's abilities became more limited, that business was sold to Plaintiff Hammel early in 1994 and the d/b/a "Ultra Videos" was relinquished by Plaintiff Bellamente, and registered to Plaintiff Hammel. This remaining video store in Ridgefield Park was about 13 months in operation at the time of the MVA. Plaintiffs had taken, and continued to take as little money from the video business as possible in order that the money be reinvested in a business that was started completely new, in order to build a strong inventory that would attract customers. At the time of the MVA, by having done that, and through Plaintiffs' physical presence and business concept of the highest level of personal service, the business thrived in that one year, greatly exceeding their initially calculated growth, so that salaries might just begin to have been taken. Important to the growth of the video business was Plaintiffs' physical presence and interaction with customers, Plaintiffs made it a practice to: learn customers' names and their tastes and needs; waive late charges and give free rentals to those they learned had their own personal setbacks; and knew the movies that were being rented, and whether a given movie would be suitable for a customer's children. Plaintiffs' absences for physical and medical reasons, and their difficulty in keeping up with ordering and knowing their increasing stock were, at first, tolerated by their customers. Plaintiffs had one occasional helper in their friend, Mrs. Patricia Buser. Mrs. Buser's knowledge and abilities matched those of Plaintiffs, and her acceptance of, and dedication to their business concept made her invaluable as she tended the business, most frequently without remuneration, after the MVA, when neither Plaintiff could, to help mitigate business setbacks. In November 1994, Plaintiff Bellamente was caused to fall down stairs by MVA injury related numbness and weakness in his feet. His chiropractor immediately arranged an emergency appointment with a neurologist, and it became apparent that Plaintiff had injuries more serious than thought, requiring treatment by other than a chiropractor. This Plaintiff was referred to Peter H. Schmaus, M.D., Gary Alweiss, M.D., and other physicians. Around December of 1994, chiropractor, Dr. Peter N. Boulukos became suspicious that physical damages were present that might require other than chiropractic treatment in Plaintiff Hammel as well, and referred him to Peter H. Schmaus, M.D. In preparation for these visits to Dr. Schmaus, and others, Dr. Boulukos ordered radiologicals of the apparently insulted body parts, which indeed showed, according to radiological reports and consultations with other physicians, the existence of damages that required a more aggressive, and medical, in addition to chiropractic treatment. II. HOW business and property were permanently damaged, and how permanent personal injury was sustained by both Plaintiffs: Prolongation of benefit denial by contrived and fraudulent delays of Defendants SFI and SFM, through their patterns of racketeering activities, caused parallel business and personal setbacks to be thrown into an indefinite future, and were cumulative, as Plaintiffs became unable even to plan appropriately. There was a point after the denials when Defendants SFM and SFI began to cause damages that were not reversible. It was their denials and delays as acts committed within the enterprises that caused actual property and business damages by wasting Plaintiffs' time and energy to deal with SFI that would otherwise have profitably been spent on operating Plaintiffs' businesses. If not for the intrusion of these racketeering enterprises, these business damages would never have occurred. Plaintiffs business prospered beyond their expectations, within their period of business' existence due to Plaintiffs' attention and good management until the racketeering schemes of the Defendants interfered considerably with that attention and good management. Moreover, Plaintiffs' daily activities ineluctably shifted from their proper businesses to the daily chores of attempting to deal with Defendant SFI in the matter of its unlawful denials of medical benefits stemming from its patterns of racketeering activities. The amount of necessary time and effort expended on dealing with SFI severely and harmfully distracted Plaintiffs' attention from their proper businesses. Failure of Plaintiffs' attention to their businesses, already being hampered by the lack of appropriate treatment of their physical injuries resulting from the accident, and being exacerbated by having to deal with SFI's unwarranted intransigence in parallel, caused further business injuries, leading from rapidly declining income to loss of property: the inability to pay business debts caused Plaintiffs to liquidate personal property, which was insufficient to prevent foreclosure on Plaintiff Bellamente's residence, which both Plaintiffs occupied and in which Plaintiff Hammel had a money interest. Though, initially, there were both business and property damages, and also physical and other personal damages, these ran in parallel, as opposed to business damages having been solely caused by the physical damages. Permanent physical damages may be one much later proximate cause of permanent business damages, which is to say the inability to ressurect a business of any sort, but that is not the the direct damage in their RICO claims of the first first epoch in New Jersey. The prolongation of the racketeering activities of the enterprises, even into the litigation process itself, is the overriding cause of both permanenancy of business and physical failures, separately and together. Both epochs separately are the issues in this action. The video business and the computer consulting business owned by Plaintiff Hammel were both run, not as corporations, but as d/b/a's. Thus the notion of business, business property, person and personal property were not distinct entities. A registered d/b/a preserves a "business name" that is attached to the person who is doing business. The d/b/a, which is the business is, in fact, simply a protected name for the person. Setbacks and damages to business were compensated by personal reserves. That a business setback or loss is also a personal setback or loss is a result of Plaintiffs prudently attempting to mitigate their damages by preserving business and income, not a result of direct personal damage. The denials, delays, deceit, and trickery, used to hide essential fraud, extortion, breaches, and other torts committed by defendants acting within the enterprises in patterns of racketeering activities have: a. caused large additional business and property damages as a result of acts committed by defendants within the enterprises, changing what would have been setbacks into irrecoverable and irreversible damages. b. made all damages irrecoverable, except by Plaintiff's present action in this Court. These acts, and their continuation despite repeated notice to SFI over a period of five (5) years have each, separately and together, contributed to: a. causing great further physical damages b. making the physical damages of a. irrecoverable and irreversible, causing c. a. and b. causing debilitating and long term, and possibly permanent psychological damages d. a., b. and c. causing further physical and property damages, and the destruction of future income and life as it was known to Plaintiffs e. a., b., c. and d. creating future damages which require extraordinary financial, physical, psychological and medical support for the remainder of both Plaintiffs' lives. Permanent Personal damages that arose from the claims handling tactics, which are an inherent scheme in the Defendants' SFI and SFM's patterns of racketeering activities, put both Plaintiffs in the economic position of not being able to transcend the denials of medical benefits and proceed with medically necessary surgeries. Surgeries were eventually performed when Plaintiffs, deprived of all income by Defendants, became sufficiently impoverished to be able to receive Medicaid under SSI, in North Carolina. Though SSI qualification merely confirmed disability on medical grounds, it is clear that Plaintiffs' disabilities and their impoverishment did not appear magically at that moment. The actual financial disabilities were the reason for Plaintiffs' move from New Jersey to their current residence in one of North Carolina's most remote and isolated areas. When through a business damage, a personal damage is caused that disables a person from all physical activities he has previously known, this is an even more grievous damage than should all his business and property simply be destroyed. In the latter case, it is still possible, though perhaps difficult to start anew. In the former case of extensive disability, even this option has been removed, so that business and personal damages stemming from continued business damages are both irrevocable and irreversible. Unless both business and property damages, and personal damages are all compensable under the conditions of this case, business and property damages, compensable under RICO, become, in fact, not compensable, thus violating the notion of compensability as prescribed in the statutory language. This is a particular case where personal damages should be allowed as coalescent with business and property damages in conformity with the provision of RICO's Liberal Construction Clause, that this title "shall be liberally construed in order to effect its remedial purposes." One should then ask: what are the remedial purposes of RICO? From the RICO Statute, one reads in the: Congressional Statement of Findings and Purpose "It is the purpose of this Act [see Short Title note above] to seek the eradication of organized crime in the United States by strengthening the legal tools in the evidence-gathering process, by establishing new penal prohibitions, and by providing enhanced sanctions and new remedies to deal with the unlawful activities of those engaged in organized crime." Also, in SEDIMA, the Court finds the remedial purposes of RICO powerfully expressed in 1964(c), empowering its civil remedies. In their Memorandum in Support of Motion to Dismiss, or in the Alternative to Stay, at II(A), Defendants argue: "An allegation of personal injury and pecuniary losses occurring therefrom are not sufficient to meet the statutory requirement of injury to "business or property." (Bast v Cohen, Dunn & Sinclair, PC, 59 F.3d 492, 495 (4th cir. l995) See also (McMurtry v Brasfield, 654 R. Supp, l224-25 (E.D..Va.l987) (plaintiffs lacked standing to sue for emotional distress and similar personal injuries.) Plaintiffs have already argued that, in this case, the concepts of "business and property" damages may not be, in actuality, as distinct from "personal damages" as they might ordinarily be construed because of the special circumstances of this action. In Bast, the only injuries claimed were indeed personal, and only "extreme mental anguish" resulting from the acquisition of knowledge; there were no business or property damages, nor were they alleged. These citations then, are not all applicable to the facts and allegations of this action. Most Courts hold, even outside of RICO, that personal damages in the form of mental distress, anguish or anxiety are not compensable unless there has been an underlying physical damage from which it results or with which it is associated. Mental anguish or distress alone is generally not compensable, except under certain unusual circumstances. Applying the mold, and therefore the conclusions, of the constructions in damages of the Bast Court to the present case is inappropriate. It does not fit the present facts nor Plaintiffs' constructions. Medically, it is well known that emotional damages can be involved in a cyclic way with physical damages; and it is clear that emotional damages can also be similarly involved with loss of business and property, most especially when the business is the person. The causal relationships approached using the usual proximate cause analysis becomes quickly a nexus of proximate causes rather than a tree of relationships, and followed further becomes an imprecise froth of causal relationships from which a subfroth that might be labeled "personal", cannot be reasonably extracted. Defendants subsequently go on to say: "Put another way, there must be a 'discernible causal connection' or 'nexus' between the acts of the defendant and the complained-of harm to the plaintiff. (HMK Corp. v Walsey, 637 F. Supp. at 716)." Plaintiffs do not see that this is the same thing put another way, but, nevertheless, show in their amended complaint, based on new evidence, that such a nexus of acts by Defendants has caused the totality of damages herein complained of. Defendants also state: "Because the personal injuries and pecuniary losses alleged in the Complaint resulted from a motor vehicle accident, and were not proximately caused by any alleged conduct by Defendants, Plaintiffs lack RICO standing." Either Plaintiffs have not been clear, or Defendants have misread Plaintiffs' allegations. In either case, Plaintiffs' Amended Complaint is clear on the allegations, that the severe, irrecoverable and irreversible damages to Plaintiffs are indeed the result of "conduct by Defendants" in their patterns of racketeering activities. In the cases cited by Defendants, the facts of the cases did not include discernible business or property damage at all, and those plaintiffs sought damages of emotional distress only, or sought business or property damages that were not real or substantive. Plaintiffs in their Amended Complaint do show a causal nexus leading from Defendants' activities and substantive damages to Plaintiffs. The facts of cases cited by Defendants do not fairly meet the facts of the present case and so are misapplied. It is true that as a result of the MVA of September 16, 1994 plaintiffs experienced pain, and sought conservative treatment. When the conservative treatment was determined not to be effective, Plaintiffs, in consultation with Dr. Boulukos, sought further investigation of the cause of the pain. Then, through various radiologicals the source of pain was discovered, early in 1995. Proper, yet prudent action was taken, first in Plaintiff Bellamente's case, since, at the time, his condition was the more serious. Simple pain as the result of a simple acute injury is not a permanent injury, but rather a symptom; but, pain can and did cause injury to Plaintiffs' businesses. Through the knowing prolongation, by Defendants, of that pain, and the underlying reversible injuries suffered, by Plaintiffs this action; through Defendants predicate acts and their patterns of racketeering activities, the prime and first real injury is, in fact, the damage to Plaintiffs' businesses. From this injury, a complicated nexus of further injuries flowed, reinjuring business and property, as well as creating irreversible injuries to neurological systems, in turn causing injuries to the total body and to both Plaintiffs by removing their capacity to "work steadily" at anything. Indeed, even this very extortionately forced litigation itself is simultaneously economically, physically and emotionally damaging to both Plaintiffs. III. A conservatorship as a business (source of income) is personal. A d/b/a is a personally conducted business: damage to business and property can cause personal damages, and damage to person can cause business and property damages. In fact, the lines between personal damages and damage to business and property in the case of a d/b/a are merged, even to a greater extent than they would be in a Subchapter S Corporation, where losses of the corporation may be taken as personal losses for purposes of personal income tax. IV. Plaintiffs present the following relevant hypothetical: Suppose there were a person whose sole "business", (the activity from which he derives the income that supports his existence) was a calligrapher and that he was right handed. As a deliberate result of his being the victim of a collection of racketeering activities, his right hand was cut off. How to analyze the injuries? One could argue that the primary injury was personal, indeed physical, and that any injury to his business flows directly from the removal of his hand on the basis that in temporal sequence the personal injury occurred first and that his loss of business doesn't happen at the time of the personal injury, but is rather spread out into the future. So, possibly, the personal injuries as well as the business injuries would not be compensable under RICO since the alleged causal line of types of injuries is personal (physical) -> business -> property The essential postulates of this argument are that 1) A single act may have only a single result 2) If injuries are related, then they must be causally related. The postulates 1) and 2) are restrictive as to reality. The fact is that any act or event can have multiple consequences some of which reach into the future. Simply consider a person's death. One could then better argue that there was a primary "act", namely the cutting off of the hand, which had simultaneous multiple proximate injuries as consequences: 1) Personal injury to body 2) Immediate injury to business with long range consequences that include: a) Losses of income b) Loss of property stemming from 2a) c) Further personal injuries stemming from financial inability 2a) and 2b) to repair injury 1) 3) There arise future damages to the totality of all possible businesses that are peculiar to this particular person. The essential postulates of this argument allow that: 1) An act may have simultaneous consequences 2) An injury may extend over time (permanency) 3) Injuries may be related in ways other than by direct causal links. Even in this simple model case, the distinctions between business injuries and personal injuries are blurred in reality since the person *is* the business, so a physical damage is simultaneously a business damage and personal damage. Though this is a simplified hypothetical model, it is real enough to fit the situation where a racketeering enterprise, engaged in counterfeiting, might punish an engraver for refusing to engrave. The model also fits the situation of this case. Given Congress's stated purposes, Plaintiffs find it difficult to believe that Congress would arbitrarily intended to deny the injured party relief in such a case. It is unlikely that Congress intended to deprive of remedies a particular subset of citizens whose members consist of those who are self employed, making them as less than citizens under Federal law by denying them access to the law and due process, because their business happens to be small enough so as not to need the protections of incorporation. V. Plaintiffs recite the Statutory language: 18 U.S.C. 1964(c) "Any person injured in his business or property by reason of a violation of section 1962 of this chapter may sue therefor in any appropriate United States district court and shall recover threefold the damages he sustains and the cost of the suit, including a reasonable attorney's fee, ...." Although this section of RICO seems to require that business or property damage must be alleged, it does not read, nor is it explicit in an exclusionary or prohibitive way of other damages that may also be alleged and recovered. In language, "the damages he sustains ...", and not, "these damages he sustains ...", shows that the sustained damages for which remedy is available do not refer back to the required damages. By language, subsection 1964(c) leaves open what the full extent and nature of the sustained and recoverable damages may be. Had Congress intended that compensable damages be completely unrestricted, it might have written "any damages he sustains"; it did not so write. Using the simple article "the", not choosing the reflexive construction "these", signals an intent that "the damages" may not be any separate damage, but must be connected in some proximate way to the required damages to "business and property". Moreover, in SEDIMA, the court held that there was no such thing as a "racketeering injury", and that despite the suggestion in 1964(c) that injury had to flow from a violation of 1962, the Court argued that eventually the injury could also flow from the predicate acts of 1961, using the liberal construction clause. In the dissenting opinion of Justice Marshall, with whom Justice Brennan, Justice Blackmun, and Justice Powell joined dissenting: "In addition, the statute [RICO] permits recovery only for injury to business or property. It therefore excludes recovery for personal injuries. However, many of the predicate acts listed in 1961 threaten or inflict personal injuries - such as murder and kidnaping. If Congress in fact intended the victims of the predicate acts to recover for their injuries, as the Court holds it did, it is inexplicable why Congress would have limited recovery to business or property injury. It simply makes no sense to allow recovery by some, but not other victims of predicate acts, and to make recovery turn solely on whether the defendant has chosen to inflict personal pain or harm to property in order to accomplish its end." has argued against the broadening of the interpretation in the flow of damages, thereby seemingly reducing any exclusionary or prohibitive interpretation regarding the types of damages that may be alleged and recovered, reductio ad absurdum. However, if one accepts the reasoning of SEDIMA, and then follows the logic of Justice Marshall, the step in logic does not have to be that of Justice Marshall that the flow of injury should never have been broadened in the first place, but rather that it has indeed been broadened, and that this necessitates a further logical broadening in the concept of what damages are actually compensable. Plaintiffs note that SEDIMA does, in fact, state that in regard to violations of 1962(c), "In addition, the plaintiff only has standing if, and can only recover to the extent that, he has been injured in his business or property by the conduct constituting the violation." in reading the Statute regarding recoverable damages, although this severe restriction is not literally present in the Statute per se; the dissenting Justices are also then at odds with that inclusion on the bases of equity, logic and reason. With respect to the opinion in SEDIMA, it is possible to reconcile Justice Marshall's dissenting argument with the majority opinion, by making the extension that Justice Marshall actually suggests, and arriving at a consistent statutory interpretation. THEREFORE, the court should construe the remedial powers of RICO within its literal wording regarding damages that may be recovered, in this case, and construe those remedial powers in terms of the equity, logic and reason of statutory entirety, and the intent of the liberal construction clause. To allow that although business or property damages must be present, and that the compensable damages must contain them, but also to allow that the totality of damages compensable may be greater than simply and strictly those of business or property. Not to construe this extension of compensable damages would appear to be at odds with Court's expressed opinion in SEDIMA, combined with the language of the statute itself. 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
Hammel v. State Farm Diary
Uncivilization and its Discontents