The Progress of this case will be followed from a


in chronological order with links to appropriate documents.

Also see the Amended Complaint


             WILLIAM C. HAMMEL,                    |
             ALAN J. BELLAMENTE,                   |
             et al.,                               |      COMPLAINT IN
                  Plaintiffs                       |      CIVIL ACTION
                   vs.                             |
                                                   |      No. 2:99-cv-44-T
             STATE FARM MUTUAL AUTOMOBILE          |
             INSURANCE CO.,                        |
             STATE FARM INDEMNITY COMPANY,         |
             et al.                                |
                  Defendants                       |



             WILLIAM C. HAMMEL,

                PRO SE

             ALAN J. BELLAMENTE,

                PRO SE


             its agents, servants and/or employees;

             its agents, servants and/or employees,

             and any other as yet undiscovered parties or entities,
	     related to this action, that may come to light in
	     subsequent discovery.


             Plaintiffs complain also on behalf of other directly or
             proximately injured parties, which injury or damage arises
             from Defendants' tortious actions which made necessary certain
             existing contractual agreements, to insure Plaintiffs' survival.
	     These parties are:

             The Federal Government of the U. S.;
             The Social Security Administration of The U. S.;
             The Government of the State of North Carolina;
             The Government of the County of Graham, North Carolina;
             Donald A. Walton, of Rutherford, New Jersey;
             Mountain Area Information Network, of North Carolina;
             Plaintiffs' various healthcare givers who may have not been paid,
             through the systematic pattern of racketeering activity
             alleged herein;
             Others whose proper payment were unnecessarily
             delayed with exactly the same purpose and motive,
             of which Plaintiffs complain herein;
             as well as other unknown injured parties that
             may yet be discovered.

             These parties are included in accordance with the
             provisions of FRCP Rule 71.


                I. JURISDICTION         paragraphs   1  -   10

               II. VENUE                paragraphs  11  -   13

              III. STANDING AND
                   RIGHT TO RELIEF      paragraphs  14  -   17

               IV. BACKGROUND AND
                   FACTS OF THE CASE    paragraphs  18  -   86

                V. LEGAL POSITION AND
                   OF SPECIFICS         paragraphs  87  -   92

               VI. CAUSES OF ACTION     paragraphs  93  -  101

              VII. REGARDING THE
                   "ENTERPRISE"         paragraph  102  -  102

             VIII. RELIEF SOUGHT        paragraphs 103  -  110

               IX. DEMAND FOR JUDGMENT  paragraph  111  -  111

                X. PLAINTIFFS' AVERMENT paragraphs 112  -  114

	        A. Exhibit

	        B. Exhibit


        Plaintiffs aver on information and belief, and upon reasonable
        investigation and research that Federal RICO laws 18 USC 1961-1968
        do not frustrate the goals of any laws regulating insurance in either
        the States of North Carolina or of New Jersey, and further that
        The Western District Federal Court of The State of North Carolina
        has jurisdiction in this matter:

        1) Federal District court has jurisdiction by statute under
           1. 18 USC 1964(a)
           2. 28 USC 1331
           3. 28 USC 1339

        2) There is Diversity of Citizenship, 28 USC Sec. 1332
           regarding the tortious actions alleged and violations of
           18 USC 1962 (RICO), and 18 USC 1951 (Hobbs) by Defendants,
           since continuity of these actions spans a time when Plaintiffs
           lived in the State Of New Jersey until February 1996, and
           thereafter in the State of North Carolina.

        4) There is a further complete diversity of citizenship since the
           Defendants' States of incorporation are the State of Illinois
           and possibly New Jersey, while Plaintiffs are residents of the
           State of North Carolina.

           Plaintiffs' allegations are directly against State Farm
           Indemnity, a wholly owned subsidiary of State Farm Mutual, and
           therefore also against State Farm Mutual which does business in
           many States of the United States; the home offices of State Farm
           Mutual are in the State of Illinois, of which it is a citizen,
           while State Farm Indemnity, upon information, belief and reasonable
           investigation is licensed only by the State of New Jersey, and the
           State of Illinois to do business only within those States, and
           that it does business only or primarily within the State of New

        5) The Parent company, State Farm Mutual does business in the State
           of North Carolina and has representatives in  The Western District
           of North Carolina.  On information and belief, State Farm Mutual
           is a Foreign Corporation doing business in the State Of North

        6) Based on the preceding, the allegations contained herein
           constitute a matter which affects Interstate Commerce, and
           presents a condition of "complete diversity of citizenship"; the
           matter, therefore, falls within Federal Jurisdiction, and
           specifically again under 18 USC 1951(b)(3) of the Hobbs Act.

        7) Although there does exist a RICO provision in the North Carolina
           General Statutes, GS 75D 1-14, which appears to be an elaboration
           of 18 USC 1962, and explicitly prohibits the prohibited acts of
           18 USC 1962, Plaintiffs cannot find such a cognate provision in
           the State of New Jersey.  From these circumstances and further
           supporting documentation, it is the conclusion of Plaintiffs
           that their appropriate pleadings would be unwelcome in the State
           Courts of both New Jersey and of North Carolina.

           All the preceding leaves the pursuit of justice possible only
           within the jurisdiction of the Federal Western District Court
           of North Carolina.

        8) There is relevant Federal law regarding patterns of racketeering
           activity, RICO, and specifically also with regard to
           both mail and and wire fraud, 18 U.S.C 1341 and 18 U.S.C 1343
           respectively, as well as extortion, (Hobbs).  Therefore, The ERIE
           doctrine is irrelevant, and the matters herein should be considered
           only within the bounds of Federal Law.

        9) The federal law of the preceding paragraph is not in any
           "direct conflict" with any laws of the States of New Jersey
           or North Carolina, and specifically it does not "invalidate,
           impair, or supersede" any laws of these States which regulate
           insurance. U.S. Sup. Ct. Humana v. Forsyth, Certiorari, for
           9th Cir. No. 97-303.

        10) The amount of controversy well exceeds the statutory sum
           of $75,000.

        II. VENUE:

        The Western District Federal Court of North Carolina is the
        only appropriate venue in this matter:

         11) Plaintiffs reside, and have resided in Graham County,
             North Carolina for longer than three (3) years; Graham
             County lies within the Federal Western District of
             North Carolina.

         12) The Parent company, State Farm Mutual does business in the State
             of North Carolina and has representatives in  The Western District
             of North Carolina.

         13) Any change of venue to a different district, for
             whatever reason, would cause such economic hardship, physical
             distress and possible physical injury to plaintiffs so
             that this case could not be litigated, and would negate,
             utterly, the pursuit of justice.


        The Plaintiffs have standing in this matter, and in the The Western
        District Federal Court of North Carolina:

        14) Plaintiffs reside, and have resided in Graham County,
            North Carolina for longer than three (3) years; Graham
            County lies within the Federal Western District of
            North Carolina.

        15) Plaintiffs had a written and signed auto insurance policy
           with State Farm Indemnity of New Jersey, a wholly owned
           subsidiary of State Farm Mutual Insurance Company, against
           which Plaintiffs now claim multiple causes of Federal action.
           A properly filed claim with some of its documentation for an
           MVA [September 16, 1994] in the State of Jersey was transferred,
           at some indeterminate time from State Farm Indemnity
           to State Farm Mutual in the State of North Carolina, without
           Plaintiffs' request, knowledge or consent.
           Plaintiffs' change of State residence was not a manoeuvre
           for the purpose of creating a diversity, but was, in fact,
           an action that was forced upon plaintiffs by the continued
           malicious, prohibited acts of Defendants, and an action prudently
           dictated by the threat of financial disembowelment, foreclosure,
           loss of all income, and physical damages, all of which actually
           came to pass, despite Plaintiffs efforts to avoid same.

        16) This is a matter which devolves upon the interference by
            Defendants, in legitimate interstate commerce through its
            genuine pattern of racketeering activities.

        17) Plaintiffs have been "stonewalled" by Defendants actions in denying
            covered benefits, and delays, continuously since July 27,
            1995, for no ascertainable reasons.  In matters of performance
            on PIP and UIM there are actions before the State Courts of
            New Jersey in Bergen County, with docket numbers: BER L 8964-96,
            and BER L 8465-96 where Defendants have continued to stonewall,
            without legitimate reason, in every aspect of discovery:

                1. failing in complete disclosure of pertinent documents
                   in their possession as demanded, by providing only
                   approximately 10% of what was available;

                2. repeatedly avoiding depositions, even under Court Order;

                3. avoiding additional depositions, even to this time.

            Under Defendants' continuing deceit, abuse of process and
            such malicious persecution, Plaintiffs wither and have been
            left no choice but to seek justice within Federal Jurisdiction,
            on grounds of Defendants' racketeering activities.


          18) Plaintiffs together held the auto insurance policy 
              X14107-A12-30, with State Farm Indemnity of New Jersey.

          19) Plaintiffs owned, jointly, but not as tenants in common,
              a 1992 Mercury Grand Marquis automobile, bearing VIN
              2MECM75WXNX660755, with valid New Jersey registration
              plates "WH AB".

          20) On September 16, 1994, at or about 10:00 PM EDST
              Plaintiffs sustained physical injury as a result of a
              rear-ending MVA, without fault of Plaintiffs.  The
              policy in 18) was paid up and in force at that time.

          21) Plaintiff Bellamente was driving at the time of the MVA
              of 20) and both Plaintiffs were wearing seatbelts as
              prescribed by the State Laws of New Jersey.

          22) Plaintiff Bellamente had almost completely recovered,
              through conservative treatment, from an MVA which occurred
              on August 6, 1992, in which he was not at fault.

          23) The tortfeasor's insurance company in MVA of 20) quickly
              paid the limit of his policy after Plaintiffs' surgeries,
              against which Defendants have already subrogated.

          24) As a result of the prior MVA of 21), Plaintiff Bellamente's
              incapacity to work forced Plaintiff to close two video
              rental stores, a loss that has never been properly compensated.

          25) As a result of this incapacity to work, Plaintiff Bellamente
              sold to Plaintiff Hammel, the remaining video retail
              store.  Because of the MVA referred to in 20) of this
              section, two video retail stores had to be closed,
              although no compensation of any kind was ever sought,
              or had.

          26) Plaintiff Hammel had never sustained injury from any MVA,
              and has never claimed injury for such, until the MVA of
              September 16, 1994.

          27) As a result of the MVA referenced in 21) of this section,
              and Plaintiff Bellamente's incapacity to to work during
              the period of recuperation, it was necessary for Plaintiff
              Hammel to purchase and operate the business, with help from
              Bellamente as he could give it. The business was run as a

          28) From about 1981, Plaintiff Hammel was a computer consultant,
              systems analyst and programmer for law firms specializing in
              tort law, and continued in this capacity until September 1995,
              when worsening physical condition prevented it.

          29) The MVA caused immediate problems for Plaintiff Bellamente
              who was immediately taken to Holy Cross Hospital
              by ambulance.  Plaintiffs believe that at that time
              no spinal cord injury was diagnosed, and that cervical
              spasm was noted.  The diagnosis was cervical
              sprain.  He declined medications, and was released.

          30) Plaintiff Hammel followed and retrieved Plaintiff Bellamente
              from the hospital that night of September 16, 1994,
              since the automobile was still in drivable condition.

          31) After retrieving Plaintiff Bellamente from the hospital,
              Plaintiff Hammel began experiencing spasm of both lower
              back and neck.

          32) On the morning of September 17, 1994 Plaintiff Hammel
              was barely able to get out of bed.

          33) Both Plaintiffs saw Peter Boulukos, D.C., the following
              morning. Dr. Boulukos took X-rays and began treatment
              for what was considered, at that time, minor injuries.

          34) All papers and reports for claim with Defendants were
              filed in a timely way.  The claim number is 30-3204-312.

          35) Prior to the 09/16/94 MVA of 20), both Plaintiffs were in
              excellent physical health and in good physical condition.
          36) Prior to the 09/16/94 MVA of 20), both Plaintiffs were in
              prospering businesses.
          37) On information and belief, Defendants have not fully
              paid for conservative treatment for injuries sustained,
              from September 17, 1994 through about July 26, 1995.

          38) From the summary denial of all medical benefits on or
              about July 26, 1995, no request was made by defendants
              for an IME until the request for an IME in a letter from
              Defendants dated September 21, 1995.

          39) On November 6, 1995, Plaintiff Hammel went to his
              Internist, Paul S. Sender, M.D. as a result of a sudden
              onset of heart palpitations while in a state of severe
              anxiety.  An immediate EKG revealed a newly present Left
              Bundle Branch Block (LBBB).

                  1. Plaintiff had had no illnesses of any kind
                     immediately prior to this, or at this time.

                  2. The first prescription of Klonopin was given at
                     that time for "severe anxiety".  Elevated BP
                     and pulse rate were noted.

                  3. Dr. Donald Carringer, Robbinsville NC ordered a
                     Cardiac halter for possible bradycardia, which
                     tests positive.  He referred Plaintiff Hammel to
                     Dr. A. Earl Haddock at Harris Regional Hospital.

                  4. Dr. Haddock, chief cardiologist at Harris Regional
                     Hospital, Sylva NC performed a thallium stress test
                     which revealed decreased left cardiac throughput.
                     October 30, 1997.

                  5. Heart Catheterization was performed by Dr. Hanich at
                     Mission Memorial Hospital in Asheville on
                     November 7, 1997 which revealed no infarction and
                     only insignificant arterial narrowing.

          40) The various acts forming a pattern of racketeering
              extending from about July 26 1995, to December 4, 1995
              are described in the two complaints that were submitted
              to the New Jersey Department of Insurance Consumer
              Complaints, (NJDICC) submitted as Attachments A and B.
              The specific acts were:

                   1. The repeated switching of claims adjusters.

                   2. The repeated losses of documents

                   3. The repeated inabilities to find "the file".

                   4. The repeated failures of callbacks

                   5. The complete ignoration of medical reports of
                      serious nature.

                   6. The repeated delays in every aspect of claims

                   7. Mendacity regarding medical statements.

                   8. The complete ignoration of Plaintiffs'
                      communications regarding this mendacity.

                   9. The assignment of physicians who were known
                      to render reports that were in the company's
                      favor, and whose actual examinations were
                      almost nonexistent.

                  10. Arrogance and abusiveness toward Plaintiffs.

                  11. Continuous insistence on the validity of Defendants'
                      maintained, arbitrary and insubstantially based
                      denial of all medical benefits, contrary to medical

                  12. A reckless endangerment of Plaintiffs' health,
                      which has resulted in severe damages, by this
                      pattern of fraud and extortion, and conspiracy
                      to commit the fraud and extortion, among the
                      named Defendants.

                  13. A pattern of fraud and extortion causing Plaintiffs
                      justified fear and anxiety over losses that caused
                      both Plaintiffs to seek and continue to seek
                      psychotherapy, as well as to force the litigation
                      in New Jersey concerning performance, and further,
                      the agony of this litigation, which addresses the
                      fraudulent and extortionate means and intent by
                      which Defendants still avoid performance.

                  14. These patterns of racketeering activity began
                      at approximately the same time that the physical
                      damages were ascertained to be of a serious
                      nature that would require surgery.

                  15. These patterns of racketeering activity, fraud,
                      conspiracy to commit fraud and extortion were
                      committed using communications by mail.

                  16. These patterns of racketeering activity, fraud,
                      conspiracy to commit fraud and extortion were
                      committed using communications by telephone
                      and FAX.

          41) Attachments A and B were received by NJDICC, assigned
              case numbers 95-78255 and 95-78257.

          42) The investigator for NJDICC on these complaints was a
              Mr. Robert Only.

          43) Plaintiff Hammel sent eight (8) fax updates to Mr. Only,
              who made it clear on first phone conversation that Plaintiff
              was not to call him personally.

          44) Copies of these complaints were sent to New Jersey State Senator
              Byron Baer, and to New Jersey Representative Loretta Weinberg,
              the office of the Governor of New Jersey as well as
              The Attorney General, and the State Insurance Department
              of New Jersey, among others.

          45) The physical, emotional and financial conditions of both 
              Plaintiffs, coupled with attempts to maintain and also sell
              the remaining video store business and the exhaustion from
              writing those two complaints, made it clear that Plaintiffs
              were in a situation incompatible with life.  Plans were
              made to salvage what could be salvaged and move to the
              quiet mountains of North Carolina as a desperate attempt
              to preserve what was left of body, sanity and spirit.

          46) To aid Plaintiffs in relocating, their long time friend
              Mr. Donald Walton of Rutherford, New Jersey lent a total
              of approximately $15,000.  This sum has yet to be repaid.

          47) On or about January 18, 1996, Plaintiff Hammel received a
              phone call from Linda Matthews who said she was State
              Farm's Chief claim representative for Eastern New Jersey.
              She opened with, "I understand you are not satisfied with
              State Farm's handling of your claims."

          48) The conversation with Ms. Matthews was pleasant, and
              Plaintiff regarded this, finally, as an act of good faith.
              The issue most fully discussed was that of State Farm's right
              to an IME, which neither Plaintiff had ever denied.

              We agreed upon a suitable neurosurgeon for IME, a Dr.

          49) Copies of the complaint exhibits A and B were on or about
              January 18, 1996 in Defendants' possession and remain
              in Defendants' possession.

          50) No answer, substantive affirmation or denial of any
              statement in Exhibits A and B were ever received from

          51) No answer, substantive affirmation or denial of any
              statement in Exhibits A and B were ever received from

          52) There was never any indication, in the form of a report
              from NJDICC, ever seen by Plaintiffs, or seen
              by anyone with whom Plaintiffs have ever had any
              communication.  There is no evidence then, nor indication
              nor any information that indicates that any investigation
              by NJDICC exists, or was ever performed.

          53) After telephone conversation with Ms. Matthews on or about
              January 18, 1996, Plaintiff Bellamente immediately set
              upon the task of setting up an appointment with Dr. Andronico,
              but was declined appointments by his office staff saying that,
              "State Farm does not pay it's bills."

          54) Since declining IMEs with Dr. Merliss in a letter dated
              November 2, 1995, no alternative physician had been
              suggested by Defendants, until Plaintiff Hammel's conversation
              with Ms. Matthews, on or about January 18, 1996

          55) Plaintiff Hammel collected all the medical documents
              indicating substantial injury, need for treatment and
              logically sound objections to Defendants' continued
              denial of benefits, and faxed them all to Ms. Matthews,
              with a covering letter quoting the response from
              Dr. Andronico's office regarding IMEs for Defendants.

          56) All documents sent to Ms. Matthews except the covering
              letter had been in Defendants' possession for months.

          57) No further requests for IMEs have since come from

          58) The single remaining store began to fail from
              repeated closures because of Plaintiffs' incapacity or
              need for medical treatment.

              Several attempts to sell the business failed.

              Foreclosure on residence was clearly inescapable.

          59) Plaintiffs liquidated whatever could be liquidated,
              borrowed money from friends, and moved to Graham
              County, NC with hope of mental restoration, physical
              rest and the ability to live more inexpensively and
              therefore longer.

          60) On or about February 9, 1996, knowing of Plaintiffs'
              conditions, Mr. Andreas Michael of Teaneck, NJ,
              the landlord of the video store "Ultra Videos" 288
	      Teaneck Road in Ridgefield Park NJ, had the premises
	      sealed by the Sheriff, for back rent.

              The rent owed was considerably less than the value of
              the contents of the store.

              Plaintiffs were forbidden entry and lost valuable
              personal effects as well as personal
              and financial records, as well as the business itself.

              Among the items lost was the signed contract for the
              move from New Jersey to North Carolina.

          61) Plaintiffs left New Jersey on February 11, 1996, leaving
              the last day of loading to a long time friend Mr. Thomas
              Thayer; Plaintiffs arrived in Robbinsville, Graham County,
              NC on February 12, 1996.

          62) The Movers, Mountain Movers of Sylva, North Carolina
              who were hired for the move of household items from
              New Jersey to North Carolina, despite receiving a most
	      complete inventory, failed to move one (1) out of four
	      (4) floors of valuable personal effects.  All those items
	      were lost, among them all Plaintiff's financial records.

          63) Fully 75% of what was moved had to be kept in storage
              for well over one year.

          64) When the stored items were finally unpacked, it was
              discovered that many valuable and irreplaceable
              items were absent, or damaged.

          65) Plaintiff Bellamente was an owner of the house in which
              both Plaintiffs lived, while Plaintiff Hammel paid rent
              but also contributed $10,000 to the downpayment in purchase
              of this house, while retaining no ownership under title.
              This house was foreclosed on and auctioned at Sheriff's
              sale at some time after the move to North Carolina.

          66) On leaving New Jersey, Plaintiffs left the insurance
              claim, and whatever could be done regarding sale of
              the video store, and reasoning with Mr. Michael, in the
              hands of Plaintiffs' attorney at that time John C.
              Gavejian, whom Plaintiffs had known for years.

          67) For some still unknown reason, Mr. Gavejian did not
              file a PIP suit, and became uncommunicative and

          68) Even while in North Carolina, Plaintiff Hammel maintained
              correspondence with New Jersey State Senator Byron Baer.

          69) Response from the New Jersey Department of Insurance
              finally arrived, which amounted to nothing.

          70) Senator Baer sent a copy of the report to Plaintiff
              Hammel as sad tidings; a copy was also received from
              The New Jersey Department of Insurance.

          71) In further correspondence with Senator Baer, the
              Senator agreed that this was not, in fact, a report.

          72) As the statute of limitations was approaching, Plaintiffs
              had to find a new attorney, and eventually did so through
              NJATLA: Paul Jackson, Esq. for Plaintiff Hammel, and
              Alan Genitempo, Esq. for Plaintiff Bellamente, who
              currently are handling the PIP and UIM cases in NJ.

          73) Though the trip was physically arduous, stressful and
              expensive, there was no choice but that we meet with
              Mr. Jackson in New Jersey.

          74) It was clear that both Plaintiffs had to find a good
              neurosurgeon, and searched out Dr. Michael M. Haglund,
              who had been identified indirectly through Dr. David J.
              Adams as a very good neurosurgeon, and neurologist.
              Plaintiffs sought one specifically in North Carolina,
              and one at Duke University Medical Center because of
              its reputation of excellence.

          75) In order to conserve Plaintiffs' energy and finances as
              much as possible, on the way back to North Carolina,
              Plaintiffs arranged to see Dr. Haglund at DUMC.

          76) Scheduling of Plaintiff Hammel's surgery was made for
              September 25, 1996.

          77) Although Plaintiffs were both assured by various people,
              one of whom was Joanne Johnson,
              of DUMC's billing department that given the seriousness
              of the surgery and Dr. Haglund's reputation, Defendants
              would surely agree to the surgery,  Defendants stood on
              their unwarranted denial again saying, "the case is closed".

              Plaintiffs arrived on September 24, 1996 at DUMC prepared
              for Plaintiff Hammel's surgery, only to be told of
              Defendants' continuing and fraudulent denial of clearly
              necessary medical treatment.

          78) Both Plaintiffs applied for SSI benefits because of
              disabilities on or about May 9, 1996.  Plaintiff
              Bellamente received certification on or about July 8,
              1996; Plaintiff Hammel received SSI certification
              on or about January 12, 1997.  Both certifications
              were retroactive to the date on which Plaintiffs'
              bank balance dropped below $1,000.00.

          79) Plaintiffs' surgeries were rescheduled under Medicaid:
                   Plaintiff Hammel     on  May 13, 1997
                   Plaintiff Bellamente on June 24, 1997
	      and performed thereon by Dr. Michael M. Haglund.

          80) Plaintiffs were required to travel to New Jersey for
              Defendants' depositions of Plaintiffs which
              took place regarding the PIP and UIM matters, on
              February 25, 1998 from 2:00 PM to 8:00 PM.

          81) While in New Jersey, for those depositions, both
              Plaintiffs were thoroughly examined, at Plaintiffs' own
              expense, by Dr. David Adams.  Dr. Adams confirmed Dr.
              Haglund's diagnosis of atrophied spinal cord of Plaintiff
              Hammel, and suggested that the the drug Neurontin
              (gabapentin) might be useful for relief of some of the
              various bodily dysesthesias that originate from the
              atrophied cord.

          82) While in New Jersey for depositions, Plaintiff Hammel
              was thoroughly examined, at Plaintiff's own expense, by
              Dr. Gilbert Kepecs, Rheumatologist, concerning Plaintiff's
              Right Shoulder.

              Dr. Kepecs confirmed the continued existence of
              inflammation of Plaintiff Hammel's Right Shoulder which
              had gone untreated since Defendant's initial denial of
              all medical benefits.

              In spite of several courses of physical therapy,
              range of motion and pain of the Right Shoulder had not
              improved enduringly.

          83) While visiting with Dr. Kepecs, Plaintiffs' car received
              a long gouge which appears to have deliberately been made
              by someone with a screwdriver.

          84) On return to North Carolina from Depositions in New Jersey,
              Plaintiff Hammel had to have his rectum and lower colon
              manually disimpacted at Harris regional Hospital.

          85) Final Physical Conditions of Plaintiffs as a result of
              Defendants' actions:

              Numerous and incapacitating sequelae, including, but not
              limited to:

                   1. Plaintiff Hammel
                      a) Extreme vulnerability of C-cord
                      b) Painful and weakened neck muscles
                      c) Painful and weakened upper back and
                         shoulder muscles.
                      d) General muscle atrophy and weakness, most
                         notable in abdominals, causing the already
                         injured L-spine to be painfully deformed which
                         is exacerbated by the weakened muscles of lumbar
                      e) Extreme difficulty in walking 
                      f) Bowel and Bladder dysfunction
                      g) Sexual dysfunction
                      h) Loss of coordination, balance and position sense
                      i) Great alteration in the sense of touch
                      j) Extreme burning pain in hands
                      k) Extreme sensitivity to cold
                      l) Extremely diminished stamina

                   2. Plaintiff Bellamente
                      a) Weakened and painful neck
                      b) Loss of range of motion in neck
                      c) Painful and weakened shoulders
                      d) Periodic hand pain
                      e) Sudden onsets of painful right deltoid spasm
                      f) weakened and painful lumbar back
                      g) painful mid back
                      h) dysaesthesic left foot with loss of proprioception
                      i) difficulty walking
                      j) bladder dysfunction
                      k) penile malaesthesia

          85) Physical therapy without enduring results:
              Both Plaintiffs have no enduring results from several
              courses of physical therapy.

          86) Continued psychotherapy:
              Both Plaintiffs remain in psychotherapy as a result of
              Defendants' actions and the multitudinous sequelae of those
              actions that grow like the roots of a tree.


          87) This case presents a distinction between a contractual
	      obligation, and how, and with what intent that obligation
	      is, or is not, performed.  A case of "simple" fraud, bad
	      faith, breach of contract, etc. is one thing; the underlying
	      pattern of racketeering that produces the surface appearance
	      of these simple symptoms is a different and separate matter,
              and one which can fall under federal jurisdiction. In this
              case, Plaintiffs claim this situation exists.

          88) In this case there are actions already pleaded by attorneys
              Paul Jackson for Plaintiff Hammel, and Alan Genitempo
              for Plaintiff Bellamente, for performance by Defendants.
              These are matters which fall under New Jersey's right to
              regulate insurance.

          89) Here, Plaintiffs plead not on the issue of performance,
              but rather on the issue of the pattern of actions, motives
              and intent of nonperformance, all of which extends into the
              area of due process, and its denial.

          90) Plaintiffs allege, most generally, that underlying the
	      symptoms of this clear nonperformance is a motive and
	      pattern of extortion and racketeering activity, from which
	      Defendants do derive, and knew or should have known that
	      they did derive, great financial benefit, even if perpetrated
	      on only a small percentage of claimants.

          91) It stands to reason that these violations of RICO
              and Hobbs in a pattern of racketeering activity could not
              have been applied with such aplomb, and systematic consistency
              to Plaintiffs, without inferring that Defendants have these
              systems and patterns of racketeering activities internally
              institutionalized in such a way that this is their
              "pattern of doing business".

          92) Indeed, there are other examples of these very same patterns
              being used with others of Defendants' policyholders who
              make legitimate claims.




                        a) 18 USC 1961-1968a (RICO)

                   as well as violations of

                        b) 18 USC 1951 (Hobbs Act),

                2. Tortious Interference with Contract,

                3. Abuse of the Legal Process,

                4. Malicious and Damaging Persecution,

                5. Malicious denial of due process,

              and seek relief from the Court for:

           continuing violation, and for proximate damages caused thereby,
           as outlined below.  In order to conform to FRCP Rule 8, and
           not to burden the Court, the outline in this complaint contains
           only statements, together with documentation, of the small number
           of predicate acts that are required under RICO and Hobbs in order
	   to void the anticipated motion to dismiss on the basis of
           insubstantiality.  Supporting documents submitted now are only
           a demonstration to the court that this complaint has genuine
           merit, is not an exercise in legal sophistry, and more
           importantly that it is substantive in law and in damages.

        94) Plaintiffs allege that the "predicate acts" of 98)  under
            both RICO and Hobbs, do establish a pattern of racketeering,
            and extortion, by Defendants which constitute the "enterprise".

        95) A "Pattern of Racketeering activity" is defined to be a pattern
            that has both continuity and relationship.  This pattern began
            on or about July 26, 1995 with Defendants' multiple letters of
            denial to both Plaintiffs; it continues to this moment, and
	    there is certainly a threat that such activity will continue
	    into the future.  The activities of racketeering continue, and
	    there is no evidence available to Plaintiffs that even suggests
	    discontinuance of these activities.  Continuation of this
	    pattern by Defendants is also a continuation of damages to

        96) Plaintiffs further allege that this pattern contains a sequence 
            of events, over years, that all have the same and common purpose,
            and that that purpose is one of egregiously deliberate,
	    calculated and malicious, fraud and extortion which is a
	    "pattern of racketeering activity".

        97) The particular complaints of RICO and Hobbs violations, i.e.,
            instances of predicate, and explicitly prohibited acts, for each
            plaintiff, as documented assertions, are as follows:

        98) Plaintiff Alan J. Bellamente alleges patterns of,

                1. FRAUD:
                Malicious, reckless and unwarranted denial of medical
                benefits, in the face of the written declarations of

                        David J. Adams, M.D., Neurologist
                        Robert C. Rubin, M.D., Neurosurgeon
                        John F. Pojedinec, M.D., Orthopaedic Surgeon

	        to Defendants that surgery was required for neural
	        decompression, which compression was a consequence of
	        the MVA.  The delay in surgery due to the persistent
	        pattern  of racketeering activities has produced permanent
	        neurological injuries.

                2. CONSPIRACY TO COMMIT FRAUD:

	            a) Claims adjusters named in Exhibits A and B,
	               believed by Plaintiffs to be part of an internal
	               group, all acted in agreement and concordance,
	               both written and spoken in the activities of 40).

	            b) On information and belief, Sandra Romei, supervisor
	               to this group, never indicated any variance from
	               or disapproval of these activities.

	            c) Assuming that Linda Matthews presented herself
	               correctly as Defendants' claims representative for
	               Eastern New Jersey, she did not respond to either
	               the factual medical information sent to her, or to
	               the refusal for IME by Dr. Andronico's office;
	               nor did she make any attempt to stop or condemn
	               the activities of 40).  Only her consent and aid
	               can be presumed.

	            d) It is highly unlikely, within any corporate
	               structure, that a person with Ms. Matthew's assumed
	               authority could act independently and without
	               guidance in corporate policy from yet higher

	            e) Further refusal by the parent company to address,
	               correct or condemn the activities of 40) is once
	               again, a token of consent and aid to these

                3. EXTORTION:
                The fear inducing continuation of the above malicious
                denial which exists to this moment, continuing delays,
                and abuse of process, are all causes for this Plaintiff
                to remain in psychotherapy, in addition to the requisite
                therapy for PTSD stemming from the MVA.

                4. MAIL FRAUD:
                The U.S. mail was used as an instrument of the initial
		fraud, conspiracy to commit fraud, and in the continuation
	        of this fraud and fear inducing extortion.

                5. WIRE FRAUD:
                Both telephone and FAX were used in the continued
                fraud, conspiracy to commit fraud, and in the continuation
	        of this fraud and fear inducing extortion.

        99) Plaintiff William C. Hammel alleges patterns of,

                1. FRAUD:
                Malicious, reckless and unwarranted denial of all medical
                benefits by Defendants, on or about July 26, 1995, the same
                time as Plaintiff Bellamente, not only without cause, but
                in contradiction to Defendants' own IME.

                Subsequent denial by Defendants of necessary cervical
                surgery at Duke University Medical Center, which surgery
                was deemed medically necessary and scheduled for September
                25, 1996 by Michael M. Haglund, M.D., Ph.D, Neurologist,
                Neurosurgeon.  Dr. Haglund's decision was based on thorough
                neurological examination, and MRIs that were taken well
                before Defendants' total denial of all medical benefits.
                Dr. Haglund's diagnosis was corroborated by
                David J. Adams, M.D., Neurologist.  The delay in surgery,
                due to the persistent pattern of racketeering activities
                has produced serious, permanent, degenerative and disabling
                injuries to the cervical spinal cord (atrophy).
                The surgery was finally performed May 13, 1997.

                2. CONSPIRACY TO COMMIT FRAUD:
	           Repeat 98).2.

                3. EXTORTION:
                The fear inducing continuation of the above malicious
                denial which exists to this moment, continuing delays,
                and abuse of process, are all causes for this Plaintiff
                to remain in psychotherapy, for an original and continuing
                diagnosis of "severe anxiety", in addition to the requisite
                therapy for PTSD stemming from the MVA.

                4. MAIL FRAUD:
	        Repeat 98).4
                5. WIRE FRAUD:
	        Repeat 98).5

        100) From this continuing, egregious and malicious pattern of
             racketeering and extortion by Defendants, in violation of
             RICO and Hobbs, and also because Defendants are:

             1. in violation of contractual fiduciary duty,
                before and through the litigation process of the
                cases cited in 17),

             2. as well as common laws prohibiting fraud,
                extortion and theft,

             Plaintiffs allege further that as a proximate cause of
             Defendants' Pattern of Racketeering activities, Plaintiffs
             have suffered, great, permanent and irreparable physical,
             psychological, emotional, spiritual and financial harm and
             damage, all of which has left Plaintiffs destitute, unable
             to work and unable to live as independent and productive
             human beings.

        101) Plaintiffs allege that the people, and governmental entities
             of the United States which Plaintiffs have named, and on behalf
	     of whom Plaintiffs also complain, have also been personally and
             financially damaged, through their sense of justice, and in
             their attempt to mitigate and contain, to the best of their
             ability, the damages of proximate cause that have been maliciously
             and insistently inflicted by Defendants, on Plaintiffs, over a
             period of approximately four (4) years.


        102) While Plaintiffs understand that the whole of this enterprise
             necessarily extends to The New Jersey Department of Insurance
             Consumer Protection, also to the New Jersey Department of
             Insurance, now called The New Jersey Department of Insurance
             and Banking, and even to the Government of the State of New
             Jersey, Plaintiffs decline to request waivers of State's rights
             provided under the Eleventh Amendment of the Constitution of
             the U. S., and so do not include these as Defendants in this
             action at this time.


        103) Any relief from continuing racketeering and extortion activities:
             the prohibited acts of RICO and Hobbs, under intervention
             provided in 28 USC 1367, that the court can give.
             Plaintiffs understand that, ultimately from amendments III
             and XI of the constitution and by U. S., Sup. Ct. precedent,
             this court may not remove the Cases sited in 17), in the State
             of New Jersey to this Federal District Court, thus interfering
             with the State's right to regulation of insurance granted
             by 15 USC 20 (The McCarran-Ferguson Act), but Plaintiffs see
             no reason why Federal intervention by way of court order is
             not allowed and appropriate when the actions (the how, not the
             what) of the Defendants' actions are in violation of US Code,
             and when such U.S. Code automatically has Federal District
             Court jurisdiction.

        104) Compensatory Relief in the form of $60,000,000.00 for direct
	     and proximately caused damages to life, limb, well being and
             finances of Plaintiffs stemming from Defendants' actions,
             as will be outlined and apportioned, which damages will have
             such lifelong irreparable effect as severe pain, severe
             disabilities and severe impairments, that permanently
             prohibit Plaintiffs from being self supporting, productive

        105) Such compensatory damages, plus interest, as may be verified
             and claimed by the persons and entities upon whose behalf
             Plaintiffs also complain, by virtue of existing contractual
             agreements, in accordance with FRCP Rule 71;

        106) Any and all interest accrued by debt to the Internal Revenue
             Service of the U. S., during the period of continuing pattern
             of racketeering activity, by virtue of Defendants' destruction
             of Plaintiffs' ability to pay the initial debt.

        107) Any damages, plus interest, that may be payable and due, to
             the Court itself, in compensation for whatever relief the Court
             itself may have accorded the Plaintiffs; this, since Plaintiffs'
             inability to defend themselves otherwise is a direct consequence
             of the Plaintiffs' destitution, which is caused by the unabated
             insistence on a clear pattern of racketeering activity engaged
             in within the "enterprise" that includes claimed "insurance".

        108) All Plaintiffs' Costs in this litigation, and as well, just
             compensation for the destructive and onerous work and effort that
             has been forced, under duress and extortion, upon Plaintiffs by
             Defendants' actions;  Plaintiffs request special consideration
             from the court in a determination of attorneys' fees, by the
             court, in recognition of the work done, and cost of necessary
             tools required to act as attorneys, Pro Se.

        109) Restitution of all Premiums paid to Defendants, over and above
             that which was paid as any minimum required by State Law, for
             any services that Defendants have purported to provide, over
	     any time that State Farm has ever been paid for such purported

           [Given, that these purported services, which have been provided
           in return for this money, were "insurance" in name only, and that
           Defendants' statement to the contrary was an act of deliberate
           and calculated fraud, which fraud violates and abrogates any
           agreement that may, in any way, be construed as contractual from
           any "insurance policy" with State Farm.  Plaintiffs entered
           this agreement with good faith, while Defendants entered
           it not only with "a priori" bad faith, but with "a priori"
           design of fraud and design of extortion: this just happens
           to be Defendants' "way of doing business" which Plaintiffs
           understand as the very definition of a pattern of racketeering
           activity that goes well beyond the mere "pattern" that is
           understood, in multiple definitions by the various Courts of
           the United States.]

        110) And finally, any further damages of whatever kind that the
             Court may deem suitable, just or appropriate, to Plaintiffs,
             the Court, or any persons or entities upon whose behalf the
             Plaintiffs also complain.


        111) On the basis of all the foregoing, Plaintiffs demand judgment
             for the stated relief, in trial by jury.


        112) Further extant evidence and argumentation, elucidating the
             pattern of racketeering activity, and information which will
             be acquired in the process of discovery, will establish the
             necessary preponderance of evidence as is required by the
             Court in accordance with the Federal Rules of Civil Procedure.

        113) In particular, with regard to Rule 11 of FRCP, Plaintiffs aver
             that all statements and allegations are true upon information,
             belief, and reasonable investigation, and further that this
             action is not brought with any purpose to harass or defame
             Defendants, and further that it is not of any nature that
             could be called frivolous.

	114) Plaintiffs have, in good faith, attempted to balance the
	     the necessary requirements of specificity and particularity,
	     under Rule 9(f) of FRCP to establish sufficiency of this
	     pleading, with the requirements of concision and directness
	     under Rule 8(e) of FRCP, all in accordance with Rule 11 of


        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

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

        DATE:                                 DATE:

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Created: August 13, 1999
Last Updated: May 28, 2000