The Progress of this case will be followed from a

CASE DIARY

in chronological order with links to appropriate documents.



The format of this HTML version is slightly different from the that which was submitted to the Court. It takes advantage of hyperlink possibilities that cannot exist in the hard copy edition. So relevant referential links are provided at some appropriate points, where inclusion by reference is not indicated in the hardcopy.

The hardcopy is, of course, double spaced, and paginated, while for ease of reading, the HTML version is single spaced.

This complaint, with attachments and exhibits, is long, about 1080 pages when printed out double spaced. The levels of reference is, I think, 3 levels deep. The best way to navigate it is through the OUTLINE provided below. While this file contains the complaint proper, the exhibits, attachments, affidavits and memoranda are each in separate files that are linked to from the outline.






        UNITED STATES DISTRICT COURT
        WESTERN DISTRICT OF NORTH CAROLINA
	Bryson City Division

        ____________________________________________
                                                   |
             WILLIAM C. HAMMEL,                    |
             ALAN J. BELLAMENTE,                   |        AMENDED
             et al.,                               |      COMPLAINT IN
                                                   |
                  Plaintiffs                       |      CIVIL ACTION
                                                   |
                   vs.                             |
                                                   |     No. 2:99CV-44-T
             STATE FARM MUTUAL AUTOMOBILE          |
             INSURANCE CO.,                        |
	     Robert Gordon, Asheville Supt.,       |
	     David Allen Swann, Tina Kelly,        |
	     Kimberly King, Erica Thompson,        |
	     Charles Allen, Jim Zitney,            |
	     Joan Amzler,                          |
	     and other unknown persons             |
             as employees of                       |
             STATE FARM MUTUAL COMPANY;            |
                                                   |
                                                   |
             STATE FARM INDEMNITY COMPANY,         |
             its employees: Sandra Romei,          |
             Carole Rickelmann, Jane Savastano,    |
             Linda Fernandez-Matthews,             |
             Idiana Murray, Veronica Wade,         |
	     Connie Davis, Craig Ovian,            |
	     Terri Lauria, Vivian Jones,           |
	     Catherine Muoio, Paula Nicolosi,      |
	     Sheryl Clougher, Erica Rochow,        |
	     Kevin Foth, Cynthia Rodriguez,        |
	     Diana Barrera, Gary Fifer,            |
	     Kathy Vanbreda, Donna Roff,           |
	     Kim Figaro, Lorelle A. Laub,          |
	     Anna V. Karasik, Pam Nevin-Lavender,  |
	     Lori N. Gee,                          |
             and other unknown persons,            |
	     as employees of                       |
             STATE FARM INDEMNITY COMPANY;         |
                                                   |
             Eric L. Fremed, MD, and               |
             Drs. Rabin & Fremed, P.C.,            |
	     Englewood, New Jersey,                |
                                                   |
             Sharad Wagle, MD and                  |
             Psychiatric Associates,               |
	     Hackensack, New Jersey,               |
	     individually, and as agents, servants,|
	     or employees of                       |
             STATE FARM INDEMNITY COMPANY, and;    |
                                                   | 
             Melli, Guerin & Melli, P.C,           |
             p.k.a., Melli & Wright P.C.           |
	     Paramus, New Jersey                   |
             individually, and as attorneys for    |
             STATE FARM INDEMNITY COMPANY, and     |
                                                   |
             any other as yet undiscovered parties |
	     or entities, related to this action,  |
	     that may come to light in             |
	     subsequent discovery.                 |
                                                   |
                  Defendants                       |
                                                   |
        ___________________________________________|

        SHORT CAPTION: HAMMEL v STATE FARM

        PLAINTIFFS:

             WILLIAM C. HAMMEL, PRO SE

             ALAN J. BELLAMENTE, PRO SE

        OTHER PARTIES THAT ARE NEITHER PLAINTIFFS NOR DEFENDANTS:

             Plaintiffs complain also on behalf of other directly or
             proximately injured entities, 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;
	     Duke University Hospital, Durham, North Carolina;
	     Duke University Medical Center, Durham, North Carolina;
             Donald A. Walton, of Clermont, Florida;
	     Gerald Steinfeld, of Dumont, New Jersey;
             Peter N. Boulukos, D.C., of Hackensack, New Jersey;
	     Martin M. Kluger, Ph.D., of Teaneck New Jersey (practice);
             Mountain Area Information Network, of North Carolina;
             Plaintiffs' various healthcare givers who may have not been paid,
	     or not paid with interest due them through the systematic
	     pattern of racketeering activity alleged herein;
             Others whose proper payments 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.


        DEFENDANTS, Their Agents, Servants and Employees with
	REFERENT ABBREVIATIONS:
	     
             STATE FARM MUTUAL AUTOMOBILE INSURANCE CO.,
	     BLOOMINGTON, ILLINOIS
	     hereafter, SFM
	     
             STATE FARM INDEMNITY CO., BLOOMINGTON, ILLINOIS
	     hereafter, SFI

	     Linda Fernandez-Matthews
	     hereafter, Matthews

	     Pam Nevin-Lavender,
	     hereafter, Lavender

	     All other named employees of SFI are unambiguously
	     referred to by their last names.

	     All named employees of SFM are unambiguously
	     referred to by their last names.

             Sharad Wagle, M.D.,
             hereafter, Wagle

	     Eric L. Fremed, M.D.,
	     hereafter, Fremed

             Rabin & Fremed, P.C.,
	     hereafter, Rabin

	     Douglas M. Barnett
	     David E. Rehe & Associates, Attorneys at Law
	     Meadows Office Complex
	     201 Route 17 North, Rutherford NJ 07070
	     Employees of the Corporate Law Department
	     State Farm Mutual Automobile Insurance Company,

	     Melli, Guerin & Melli, P.C.
	     (Attorneys for State Farm Indemnity)
	     West 115 Century Road,
	     Paramus, NJ 07652
	     hereafter, Melli

	     Mark Melli
	     of Melli

	     Donna T. Miller
	     of Melli
	     hereafter, Miller

	     Michelle Wall
	     of Melli
	     hereafter, Wall

   ____________________________________________________________________

                                 OUTLINE

             I. PRELIMINARY STATEMENT     paragraphs   1  -   22

            II. THE PARTIES & THEIR
                RELATIONSHIPS             paragraphs  23  -   51

           III. BACKGROUND & ALLEGATIONS
                OF FACT                   paragraphs  52  -  235

            IV. JURISDICTION              paragraphs 236  -  245

             V. VENUE                     paragraphs 246  -  248

            VI. REFERENCE MEMORANDUM ON HOBBS 
                APPLIED TO INSURERS       paragraphs 249  -  249

            VII. CAUSES OF ACTION         paragraphs 250  -  934
                A. Fraud                             250  -  382
                B. Conspiracy to Commit Fraud        383  -  502
                C. Mail Fraud                        503  -  507
                D. Wire Fraud                        508  -  512
                E. Hobbs                             513  -  549
                   1. robbery
                   2. extortion
                   3. conspiracy
                      to commit robbery
                   4. conspiracy
                      to commit extortion

                F. Counts of RICO 18 USC 1961        550  -  699
                   1. 18 USC 1962(a) 5 counts        550  -  608
                   2. 18 USC 1962(b) 4 counts        609  -  649
                   3. 18 USC 1962(c) 3 counts        650  -  684
                   4. 18 USC 1962(d) 3 counts        685  -  699

                G. Supplementary Causes of Action in Violation
                   of The Laws of The
                   State of North Carolina           700  -  934

                   1. bad faith
                   2. conspiracy to commit bad faith
                   3. intentional infliction of emotional distress
                   4. tortious breach of fiduciary duty & conspiracy
                   5. tortious breach of contract & conspiracy
                   6. tortious interference with contract & conspiracy
                   7. tortious abuse of process & conspiracy
                   8. common law fraud
                   9. conspiracy to commit common law fraud
                  10. common law extortion
                  11. conspiracy to commit common law extortion
                  12. tortious interference with due process,
                  13. conspiracy to commit
                      tortious interference with due process,


          VIII. SUMMARY OF DAMAGES        paragraphs  935 - 937

            IX. RELIEF SOUGHT             paragraphs  938 - 945

             X. DEMAND FOR JUDGMENT       paragraph   946 - 946

            XI. PLAINTIFFS' AVERMENT      paragraphs  947 - 949

             Attachments:
                     1. Memorandum on State Farm's Misconduct
                        [See separate volume]
                     2. Memorandum on State Farm Mutual & Subsidiaries
                     3. Memorandum on Hobbs applied to Insurers
                     4. Memorandum on Dr. Fremed's Report & Reviews
                        [See separate volume]
                     5. Memorandum on Dr. Fremed's review of Plaintiff
                             Hammel's medical reports
                        [See separate volume]
                     6. Memorandum on Damages and Causality

             Exhibits:
                     A - NJ DOI Complaint Hammel
                     B - NJ DOI Complaint Bellamente
                     C - NC DOI Complaint Hammel
                     D - Correspondence
                             Byron Baer
                     E - Correspondence
                             Loretta Weinberg
                     F - Esther Benevitz Phone Transcript
                     G - NJ filings
                             Motion and Order to Compel Depositions
                             [PIP release and Stipulations]
                     H - Medical
                             Boulukos letters to Savastano dated
                                     March 14 & August 3, 1995

             Accompanying Affidavits

                         Expert
                             Mark Colbert
                             Donald Carringer, M.D.
			     [See Fremed Volume]
                         Personal
                             Patricia Buser

             Accompanying Affirmation
		     William C. Hammel
   ____________________________________________________________________
			
	I. PRELIMINARY STATEMENT:


	1) This case, regardless of the seemingly endless partial
	   communications of truth by defendants, is quite simple.
	   Plaintiffs bought and relied on SFI insurance, and were
	   both injured, more seriously than anybody knew from the start.
	   SFI terminated benefits because it was profitable to do so,
	   knowing full well that there would be dire consequences of
	   their doing so.

	2) Their claims handling practices and ethics are no different from
	   their owner SFM.  Both are enterprises of racketeering "profit
	   centers" that regularly defraud their policy holder whenever
	   they feel like it.  Claims handling in SFM is itself a vast
	   collection of racketeering schemes where SFM is the invariant
	   and the attorneys and policy holders simply change from scheme
	   to scheme, a scheme in this case being a temporary nexus of 
	   connections between SFM and attorneys who will do what they
	   say and prodigal physicians who will have any "expert opinion"
	   that serves the purpose of profit.  The attorneys and physicians
	   who engage in these hundreds of thousands of schemes are paid
	   extremely well, at the expense of the injured policy holder
	   who suddenly discovers that he has no insurance.  This is
	   exactly the position in which Plaintiffs found themselves.
	   SF owns the stock of all its spawned incorporated companies
	   like SFI, and from a practical internal viewpoint, the SFM
	   company and its spawn behave, in claims handling, as one large
	   racketeering enterprise despite the fact that the spawn have
	   genuine personhood by virtue of their incorporation.

	3) In its claims handling SFM and its spawn break State and
	   Federal laws with free abandon, and use all the tactics
	   of fraud, conspiracy to commit fraud, extortion, robbery,
	   deceit, trickery, and perjury that one would expect of gangsters.

        4) In the vast number of schemes to defraud all these policy
	   holders, it saps and garners to itself an even more vast
	   depletion of the entire U.S. economy by leaving people so
	   injured that they cannot work, some with injuries made
	   permanent through SFM's racketeering schemes, but also
	   forcing their policy holders or former policy holders into
	   destitution and disability so that they must be supported by
	   some form of Social Security and Medicaid.  Money, as value
	   does not come out of thin air.  It is created by the people
	   of the U.S. and they are ultimately paying for what might
	   be tamely called SFM's unjust enrichment.

	5) Plaintiffs do not here complain of damages caused by any
	   motor vehicle accident; they complain of a paid for insurance
	   policy in contract with SFI being dealt with through claims
	   handling procedures that are a deliberately contrived
	   mechanism of racketeering that has spread from its institution
	   in SFM to all of it spawn, particularly SFI.

	6) As a "friendly fire" can turn into an "unfriendly fire",
	   the "Good Neighbor" has turned into an "Engine of Annihilation",
	   with a deaf ear to any objections, and a clear dedication of
	   purpose.  To object in Court is to invite the wrath of a hell
	   with unlimited stolen resources whose object is "to litigate
	   the Plaintiff to death".  That may be the exact result here,
	   but Plaintiffs would rather die with their boots on than submit
	   like docile sheep to the slaughter.

	7) Plaintiffs' businesses were of an entirely personal nature;
	   they have been destroyed through SFM's and SFI's unlawful
	   activities.  Both SFM and SFI have deliberately inflicted
	   physical and psychological damages that are irreversible to
	   the point that Plaintiffs are incapable of living as independent
	   productive human beings.  Business damages are also personal
	   damages, and personal damages are also business damages here.

	8) SFI and SFM have not only failed with deliberation in their
	   insurance obligations, but have inflicted a thousandfold
	   the damages that should have been covered under the policy,
	   and for which Plaintiffs will hold them accountable.

	9) These damages include permanent neurological damages that
	   that leave both Plaintiffs in severe continuous pain that is
	   unstoppable by any means, and that will continue to the
	   point of death.

       10) Therefore Plaintiffs seek to be restored to their pre MVA
	   condition in terms of functionality, in compensatory
	   damages no matter what extraordinary means that might take.
	   Further, Plaintiffs seek a punitive award of sufficient
	   argument that what SFM or SFI, or indeed "The State Farm
	   Family" has done here daren't be done again.


		THE SCHEMES OF STATE FARM MUTUAL AUTOMOBILE COMPANY

       11) SFM has many schemes to defraud its policy holders, see for
	   example the Attachments herein.  Specifically, a scheme that
	   is most devastating to holders of Personal Injury Protection
	   (PIP) policies, of which Plaintiffs herein complain.

       12) Insurance companies, and SFM and its spawn of incorporated
	   subsidiaries in particular, have the ability to deny claims
	   as well as payments to both policy holders and healthcare
	   givers at will, not, in reality, having to give substantive
	   reason, or any reason at all.  If they are forced into giving
	   some reason, the expedient partial truth is often used, as
	   Plaintiffs will show.  These partial truths are even passed
	   amongst the multitude of people who are alternately and
	   variously engaged in the handling of a claim, or in State
	   Farm's internal language, of "controlling" a claim.

       13) Beyond the powers of "delay" and "deny" exercised with impunity
	   is another powerful weapon used against injured policy holders;
	   this is the euphemistically named Independent Medical Examination
	   or IME.  As any Plaintiff's attorney knows, these allegedly
	   independent examinations, are often not even really examinations,
	   therefore not medical, and certainly not independent, as
	   Plaintiffs will demonstrate.

       14) SFI, as one of the spawn of SFM uses these IMEs as a weapon of
	   war designed to validate an a priori designed denial.  Such
	   IMEs have been used against Plaintiffs, and attempted to be
	   used against Plaintiffs in order to deny them medically necessary
	   surgery.  The IME physician is paid well for his work, and
	   coached through letters that a claimant never receives, innuendo
	   and blind addenda, post scripts and footnotes so that he knows
	   exactly what is expected of him.  Failure on the part of any
	   healthcare giver to return a report that is an excuse for
	   denial of claims often results in endless delays in payment.

       15) When an IME was not possible, Defendant SFI resorted to another
	   but weaker form of attack, the "Paper Review" wherein one
	   physician "reviews" the reports of other physicians and comes
	   to the not unsurprising conclusion that the "injuries are not
	   related to the accident".  This weapon has been used on both
	   Plaintiffs in a way that would be clearly a sham to any
	   layman.  Plaintiffs will expose these shams for what they are.

       16) Ultimately, through schemes of fraud and robbery, SFI reduced
	   both Plaintiffs to impending homelessness and destitution,
	   extorting them to bring suit in New Jersey for performance
	   on its PIP obligations.  New Jersey has no effective
	   Statutory provision for Plaintiffs to seek redress for SFI's
	   wrongdoings.  Prior complaints to the New Jersey Department
	   of Insurance (DOI) produced nothing, and it is only recently that
	   Plaintiffs have discovered that SFI, through its employees
	   told half truths, and sent irrelevant and obfuscatory material
	   to the DOI investigator.

       17) With physicians actively engaged in its nexus of schemes of
	   fraud, and robbery, and Plaintiffs extorted into a PIP suit,
	   it would be impossible to have such litigation be profitable
	   to SFI if their attorneys were not also involved.

       18) Often, insurers, and SFI in particular will choose a medium
	   sized law firm to represent them in these matters, and make
	   many cases available to this one firm.  While an attorney
	   with integrity might balk at presenting to a court, in defense
	   of his client, a document that is a clear fabrication or a
	   known lie, when a medium sized firm earns a large share of
	   its income from an insurer, and in particular from an insurer
	   engaged in defrauding its policyholders such as SFI, one does
	   not bite the hand that feeds, and so acquiesces and also
	   becomes engaged in a racketeering enterprise, conspiring to
	   produce sham evidence together with the insurer and physicians.
	   SFM's cancerous racketeering practices are then injected
	   into the very litigation process itself.

       19) This results in tortious breach of fiduciary duty by SFI,
	   tortious interference with Plaintiffs' right to due process,
	   abusive burdening of the Courts, as well as Plaintiffs'
	   attorneys, among other unlawful acts.

       20) The above picture is exactly what Plaintiffs have faced and
	   continue to face; Plaintiffs will allege and show the various
	   patterns of racketeering engaged in by the Defendants.

       21) Plaintiffs here, include by reference, their "Memorandum
	   On The Racketeering Nature Of The Misconduct of State Farm
	   Mutual Automobile Insurance Company" in its entirety.

       22) Other cases of extraordinary Bad Faith that have been
	   brought against SFM that reveal the criminal inner workings
	   of that company and its wholly owned incorporated
	   subsidiaries are:


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

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

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

   ____________________________________________________________________

            II. THE PARTIES & THEIR RELATIONSHIPS


	23) Plaintiffs William C. Hammel and Alan J. Bellamente state that
	    at all times herein during which Plaintiffs allege damages to
	    themselves through the acts and activities of the Defendants:
	    they were business associates engaged several businesses.
	    Plaintiffs were both injured in a motor vehicle accident (MVA)
	    on September 16, 1994.  At the time of this MVA, both Plaintiffs
	    were insured by State Farm Indemnity Co. (SFI), and residents
	    of the State of New Jersey.  Previously, Plaintiffs had auto
	    insurance under State Farm Mutual Automobile Insurance Co.
	    (SFM), and retained homeowners insurance under SFM at the
	    time of, and after the MVA.

	24) Plaintiff Hammel includes here by reference the entirety
	    of his personal affidavit.

	25) As a result of this MVA, Plaintiffs became exposed to, and
	    victims of the patterns of racketeering activities engaged in
	    by the Defendants.  Plaintiffs have resided in Robbinsville,
	    Graham County, North Carolina, since February 12, 1996.

	26) SFI is an incorporated, wholly owned subsidiary of SFM, both
	    of which were incorporated under the laws of the State of
	    Illinois.  SFI does business in the State of New Jersey.  SFM
	    does business in both the State of New Jersey and the State of
	    North Carolina.

	27) Jane Savastano, Veronica Wade and Idiana Murray were claim
	    specialists and employees of SFI at the time of the MVA, and for
	    some time thereafter.  Sandra Romei was a claims supervisor
	    and employee of SFI during this time.  During this time also,
	    Linda Fernandez-Matthews was a claims superintendent and employee
	    of SFI.

	28) The firm of Melli Guerin & Wright, P. C. (Melli), is a firm of
	    attorneys who represent SFI in the matters that were before the
	    the Superior Court of New Jersey in Bergen County, brought by
	    Plaintiffs through their attorneys Alan Genitempo of the law
	    firm Piro, Zinna, Cifelli & Paris, and Paul J. Jackson
	    respectively on behalf of Bellamente and Hammel; these actions
	    were filed in September of 1996; these actions are alleged by
	    Defendants SFI and SFM to have been amicably resolved, while
	    Plaintiffs are of a different opinion.  Melli still represents
	    SFI in a subsequent Under Insured Motorist (UIM) claim that
	    has yet to be put before an arbitration panel.

	29) Donna T. Miller and Michelle Wall are attorneys with the
	    firm of Melli which practices law in Bergen County, New Jersey.

	30) Defendant SFI transferred Plaintiffs' claim files to SFM first
	    to Asheville and then to Franklin when Plaintiffs sought refuge
	    in North Carolina without this ever having been requested by
	    either Plaintiff.

	31) Jim Zitney is a claim specialist with "State Farm Automobile
	    Insurance Company", at its offices in Franklin, North Carolina.
	    Jim Zitney mailed letters to Plaintiffs, in 1996, further
	    continuing their denials of benefits and spoke with Plaintiffs
	    on the telephone.  Jim Zitney, SFM, acted at the direction of
	    Idiana Murray of SFI.  In 1996, Jim Zitney issued a "Certification
	    In Opposition To Plaintiff's Application", in the Bergen County,
	    New Jersey Action of Plaintiff Hammel.  Jim Zitney (SFM) acted
	    at the direction of Donna Miller of Meli.

	32) Sharad Wagle, M.D., is a psychiatrist with Psychiatric Associates
	    of Hackensack New Jersey.  He was engaged, on or about June 8,
	    1995, by Savastano of SFI for an Independent Medical Examination
	    (IME) of Plaintiff Bellamente.  Plaintiff Bellamente presented
	    himself for that IME, under instructions from Savastano, on June
	    28, 1995.  Dr. Wagle's report was the reason given for the denial
	    of Plaintiff Bellamente's psychiatric benefits, by SFI.

	33) Eric L. Fremed, M.D., is a physician with Rabin & Fremed, P.C.,
	    in Englewood, New Jersey.  He was engaged, on or about June 8,
	    1995, by Savastano of SFI for an Independent Medical Examination
	    (IME) of Plaintiff Bellamente.  Plaintiff Bellamente presented
	    himself for that IME, under instructions from Savastano, on July
	    25, 1995.  Dr. Fremed's report was the reason given for the
	    denial of Plaintiff Bellamente's neurological benefits, by SFI.
	    "Drs. Rabin and Fremed" was paid for this IME.

	34) Dr. Fremed was subsequently engaged by Michelle Wall of Melli
	    to produce three (3) paper reviews of Plaintiff Bellamente's
	    medical records that include medical reports concerning an
	    MVA in 1991 when Bellamente was insured by SFM, and an MVA
	    in 1992 when Bellamente was also insured by SFM.  Dr. Fremed
	    was paid by SFI for these reviews.

	35) Dr. Fremed was once again engaged by Michelle Wall of Melli
	    to produce a paper review of the medical records of Plaintiff
	    Hammel.  Fremed and/or Rabin was paid by SFI for these reviews.

	36) Plaintiffs here reference each and every paragraph of
	    the Memorandum on Dr. Fremed, and his reviews as well as each
	    and every paragraph of all Memoranda included therein.

	37) On or about January 4, 1996, when Matthews called Plaintiff
	    Hammel, after receiving the Complaints [Exhibits A and B]
	    from Plaintiffs to The New Jersey Department of Insurance
	    (NJ DOI), Matthews had already fabricated a response to the
	    NJ DOI, before she had spoken with either Plaintiff.

	38) The New Jersey Department of Insurance in the person of Mr.
	    Robert Only was the recipient of, mendacious, obfuscatory and
	    irrelevant material, as well well as fraudulent mouthings of
	    of good faith by Mr. Harvey Maxey, CPCU, CLU Claim Manager
	    Metro Division, State Farm Indemnity Company, dated February
	    16, 1996, as a result of Plaintiffs' complaints to the NJ
	    DOI.

	39) Mr. Maxey's communication with the NJ DOI was, in fact,
	    fabricated by Matthews and transmitted almost word for word
	    in Maxey's response regarding Plaintiffs' complaints, to the
	    NJ DOI.  He states that "Dr. Hammel has advised that Mr.
	    Bellamente will not attend the Independent Medical
	    Examination."  

	40) On March 14, 1996, Murray spoke with Mr. Only regarding SFI's
	    unilateral transfer of Plaintiffs' claims file to SFM in North
	    Carolina.  Plaintiffs never requested or even thought about
	    such a transfer or even considered its possibility.

	41) On May 29, 1996 Plaintiffs' knowing very well that they were
	    to suffer the same fate in North Carolina from SFM as they
	    had from SFI in New Jersey, wrote the North Carolina DOI,
	    with complaints, enclosing the denial letters from both SFI
	    and SFM, together with copies of Exhibits A and B.

	42) On June 4, 1996, Zitney advised Superintendent Charles Allen
	    (SFM - Asheville) that he spoke with Mr. Timothy Peedin of
	    the NC DOI, who had called to inquire, that Peedin intended
	    to write Plaintiffs denying jurisdiction over this "New Jersey"
	    policy.

	43) Letters were received by Plaintiffs dated June 6, 1996 which
	    acknowledged receipt of the complaints.

	44) On June 17, 1996, Plaintiffs FAXED to Mr. Peedin
	    a wealth of documentation indicating that SFI's denials
	    were unlawful, and that something was very wrong with the
	    decision of the NJ DOI.

	45) On June 25, 1996, Larry L. Wilson, CPCU, CLU, Claim Manager,
	    West North Carolina Division, "STATE FARM MUTUAL AUTOMOBILE
	    COMPANY", wrote to Mr. Peedin, regurgitating the self serving
	    half-truths that had been originally fabricated by Matthews.

	46) On July 3, 1996, Plaintiffs received letters stating what,
	    on June 4, 1996, Jim Zitney had reported he would say.

	47) On September 30, 1996, Zitney of SFM in North Carolina wrote
	    to Mr. Robert Only of NJ DOI trying to explain to him that,
	    "State Farm, with the assistance of Intracorp, is in the
	    process of coordinating independent medical examinations
	    for both Mr. Bellemente [sic] and Mr. Hammel."  Plaintiffs
	    have yet to understand why an employee of SFM in North
	    Carolina was corresponding with Mr. Only of the NJ DOI.

	48) From the previous paragraphs where the DOI's of both NJ
	    and NC are involved, a clear pattern emerges of the lack
	    of corporate formalities between the parent SFM and the
	    subsidiary SFI.

	49) Although, legally SFM and SFI are distinct persons by
	    being separately incorporated, their behavior is not
	    consistent with the ostensible legal relationship.

	50) Plaintiffs reference here, their Memorandum on The Legal
	    and Real Separateness of the "State Farm Companies".

	51) The Departments of Insurance in both New Jersey and North
	    Carolina were unwitting dupes in this action.

   ____________________________________________________________________

        III. BACKGROUND & ALLEGATIONS OF FACT

  
          52) Plaintiffs together held the auto insurance policy 
              X14107-A12-30, policy form 9630 with State Farm Indemnity
	      Company in the State of New Jersey, hereafter, "the policy".

          53) 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".
  
	  54) Both Plaintiffs had been insured by SFM, in the State
	      of New York, beginning sometime in the year 1986, and
	      were changed from having SFM as carrier to having
	      SFI as carrier July 12, 1993, after having moved to
	      New Jersey.
  
          55) 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, while
	      turning into the driveway of Bellamente's house.  The
              policy was paid up and in force at that time.
  
          56) Plaintiff Bellamente was driving at the time of the MVA
              of 1994 and both Plaintiffs were wearing seatbelts as
              prescribed by the State Laws of New Jersey.
  
	  57) At the time of impact of the 1994 MVA, Plaintiff Hammel
	      was adjusting himself in his seat in order to retrieve
	      some papers with his right hand from the rear seat of
	      the automobile.
  
	  58) This positioning of Hammel has been consistently
	      documented since the 1994 MVA, yet systematically
	      ignored by defendants with whom he has had connection
	      directly or indirectly.
  
	  59) Plaintiff Bellamente was in a previous motor vehicle
	      accident for which he had no liability, on August 6,
	      1992, from which he had not fully recovered at the time
	      of the accident in 1994.  On informing SFI of the 1964
	      MVA, Savastano advised Bellamente that henceforth all
	      medical treatment was to go under the new claim number
	      30-3204-312, and that the old claim number, 30-3028-641
	      was no longer to be used.
  
	  60) Plaintiff Bellamente was insured at the time of the 1992
	      accident by Defendant SFM. Claim Number: 30-3028-641.
  
	  61) At the time of the 1992 accident,  Plaintiff Bellamente
	      hit his head, was injured by the pressure
	      of the safety harness, had dizziness and nausea.
	      He was taken to Holy Name Hospital in Teaneck, NJ.
  
	  62) As a result of the 1992 MVA, Plaintiff Bellamente
	      instituted suit against the tortfeasor, and this suit was
	      settled in early 1996.
  
	  63) Because of inability to work due to the 1992 accident,
	      Plaintiff Bellamente sold his d/b/a Ultra Videos business
	      to Plaintiff Hammel, and at the time of the 1994 accident
	      had a sole income of commissions due him from the
	      conservatorship of his elderly aunt, and modest income
	      from Ultra Videos since he stayed on as a consultant.
  
	  64) Plaintiffs moved to New Jersey in 1989 and continued to
	      purchase SFM insurance there, through SF Agent Charles
	      (Chuck) Sodaro.  On April 14, 1993, SFM
	      sent a letter to Plaintiffs stating that they would no
	      longer provide auto insurance in New Jersey, but that
	      automobile insurance would be available with SFI.

	  65) Plaintiffs accepted the change of insurer from
	      SFM to SFI, relying on previous experience with SFM, and
	      having reasonable expectations of being well insured.

	  66) The transcript of a telephone conversation of Plaintiff
	      Hammel with Esther Benevitz in [Exhibit F] is referenced
	      here in its entirety.

          67) The tortfeasor's insurance company in MVA of 1994 quickly
              paid the limit of his policy, against which Defendants had
	      already subrogated, after Plaintiffs' surgeries.

          68) As a result of the prior MVA of 1992, Plaintiff Bellamente's
              incapacity to work forced Plaintiff to close two video
              rental stores, a loss that has never been properly reversed
	      since that was prevented by the Defendants' patterns of
	      racketeering activities.

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

          70) From about 1981, Plaintiff Hammel d/b/a Lex*Data, was a
	      computer consultant, and systems analyst and programmer
	      for law firms specializing in tort law, as well as for
	      Ultra Videos Inc. and continued in this capacity until
	      September 1995, when worsening pain prevented it.

	  71) Plaintiff Hammel's businesses, i.e., sources of income,
	      before and on September 16, 1994 were a registered d/b/a,
	      known as "Lex*Data", as described in the previous paragraph
	      and a registered d/b/a known as "Ultra Videos".

          72) The 1994 MVA caused immediate problems for Plaintiff
	      Bellamente who was taken from the accident by ambulance,
	      to Holy Name Hospital. 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 x-rays, and was released.

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

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

          75) On the morning of September 17, 1994 Plaintiff Hammel
              was barely able to get out of bed, because of severe
	      pain and muscle spasms in his back.

          76) Both Plaintiffs saw Peter Boulukos, D.C., the morning of
	      September 17, 1994. Dr. Boulukos took X-rays and began
	      treatment for what was considered, at that time, minor
	      injuries.

	  77) In all of Dr. Boulukos' "attending physician reports",
	      sent to SFI, attribution of injuries of Hammel is made
	      to the MVA of 1994.  There were at least seven (7) of
	      these in the period from 10/28/94 to 12/30/94.

	  78) Dr. Boulukos was in the unique position to know of any
	      trauma to Plaintiff Hammel, since Hammel had previously
	      seen Dr. Boulukos as part of his weight training program.

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

          80) At the time of the MVA of 1994, Plaintiff Hammel was in
              excellent physical health and in good physical condition.

          81) At the time of the MVA of 1994, Plaintiff Bellamente was
	      still receiving treatment for injuries suffered in an
	      MVA of 1992 where he had no liability, and while he was
	      insured by SFM.

          82) Prior to the 1994 MVA, both Plaintiffs were in prospering
	      businesses.  The video rental business Ultra Videos had
	      indeed grown much faster than either Plaintiff had calculated
	      and anticipated.  The only reason for the decline of Ultra
	      Videos after the MVA of 1994 was the inability to deal with
	      SFI first on communications regarding the wrongful termination
	      of benefits, and then later once the fraud was realized, by
	      contacting and communicating with every political person
	      Plaintiffs thought had the ability to intervene on their
	      behalf.  With no results, Plaintiff Hammel finally the wrote,
	      the time and energy consuming, complaints to the NJDICC. 
	      This squandering of the businesses' time, energy and money
	      was demanded, for the survival of Plaintiffs, directly, by
	      the racketeering activities of Defendants.

	  83) On November 7, 1994 Plaintiff Bellamente complained
	      to Dr. Boulukos that his feet were paraesthesic and
	      were flopping.

	  84) Dr. Boulukos' office notes of that date show "feet
	      seem to be flopping.  tripping on steps going up & down."
	      as an observation by Dr. Boulukos, not, a subjective
	      complaint of Plaintiff Bellamente.

	  85) On November 10, 1994 Plaintiff Bellamente was caused
	      to fall down stairs in his home by his malfunctioning
	      feet which were a result of injuries sustained as a
	      result of the MVA of 1994 as stated in Dr. Boulukos'
	      letter to Savastano dated March 14, 1995, and again
	      in his letter to Savastano dated August 3, 1995.

	  86) On November 10, 1994 after Plaintiff Bellamente was
	      caused to fall down the stairs, Dr. Boulukos referred
	      him, on an emergency basis, to Dr. Seymour Strum, a
	      neurologist in Teaneck, New Jersey, because Bellamente
	      had suffered head trauma and was suffering hearing
	      impairment.

	  87) On December 22, 1994 Bellamente, expecting to be
	      evaluated by Dr. Joseph Willner, a neurologist in
	      Englewood, New Jersey, was examined instead by Dr.
	      Willner's associate, Dr. Gary Alweiss.

	  88) On February 3, 1995 in an interim report to Savastano
	      from Dr. Boulukos, he states, "Mr. Bellamente has been
	      under care in this office for injuries sustained in an
	      automobile accident on September 16, 1994."

	  89) On February 15, 1995 in accordance with demand from
	      SFI through Savastano, both Plaintiffs presented
	      themselves for IMEs by James F. Linder, P.T., D.C.,
	      in Ridgefield, New Jersey.  [There seems to be some
	      differences of opinion in various documents as to
	      when this happened; this is the correct date.]
	      On May 3, 1995, Plaintiff Hammel, after receiving another
	      demand from Savastano, presented himself to Dr. Linder
	      for a second IME.

	  90) On March 10, 1995 Hammel had MRIs of Cervical and Lumbar
	      Spine, and X-rays of Lumbar spine and right shoulder.

	  91) On June 8, 1995 Bellamente received an IME demand
	      from Savastano that he be examined by Eric L. Fremed, M.D.,
	      a neurologist with Drs. Rabin & Fremed, P.C., in Englewood,
	      NJ.  The copy of the letter to Dr. Fremed contained
	      blind notes indicating exactly what questions were
	      to be answered.

	  92) On June 8, 1995 Bellamente received an IME demand
	      from Savastano that he be examined by Sharad Wagle, M.D.,
	      a psychiatrist with Psychiatric Associates in Hackensack.
	      A previous erroneous scheduling for Hammel, however
	      contained similar blind notes as were sent to Dr. Fremed.

	  93) On June 26, 1995, and several times thereafter Hammel,
	      because of worsening shoulder pain, consulted with
	      Peter H. Schmaus, M.D., Paramus, New Jersey, who in his
	      letter dated October 18, 1995 to Idiana Murray at SFI states,
	      "Please be advised that I am a physician having participated
	      in the care of Dr. William Hammel for injuries incurred in
	      a motor vehicle accident on September 16, 1994."

	  94) On June 28, 1995, Bellamente presented himself, as
	      demanded by SFI through Savastano to Dr. Wagle for
	      examination.

	  95) On June 28, 1995, Bellamente returned from his IME
	      and called SFI speaking first with Savastano concerning
	      his communication problems with Dr. Wagle, who was from
	      India.  His conversation with Savastano was unacceptable,
	      and he then spoke with her supervisor Sandra Romei.
	      In his attempt to explain the difficulties to Romei,
	      she became hostile, terminating the conversation with,
	      "We won't discuss this!".

	  96) On July 25, 1995, Bellamente presented himself, as
	      demanded by SFI through Savastano to Dr. Fremed for
	      examination.
  
	  97) On July 27, 1995 all of Plaintiff Hammel's medical
	      treatment benefits under the PIP coverage of his SFI
	      policy were completely terminated, wrongfully.
  
	  98) In July, 1995, it was SFI's institutional policy to
	      terminate benefits to all it's PIP insureds, arbitrarily,
	      by a "report" system which used the last treatment date
	      recommended in IME reports as the "term" date".

	  99) SFI failed, fairly, to investigate the basis upon which
	      Hammel's claims were asserted, but instead responded
	      with an intentional falsehood as an excuse for the
	      complete denial of all benefits, although the falsehood
	      was explicit only to chiropractic benefits.

	 100) On July 27, 1995, Dr. Boulukos was sent a letter by
	      Savastano, telling him that SFI would not pay for any
	      of Bellamente's treatments after November 10, 1994,
	      because those treatments were being considered, by SFI,
	      as related to the fall of that date, which according
	      to SFI was not related to the MVA of September 16, 1994.

	 101) On July 27, 1995 Bellamente first consulted with
	      Dr. David Adams, a neurologist in Hackensack, New
	      Jersey, to whom he was referred by Dr. Schmaus.
	      Dr. Adams suspected a central rather than a peripheral
	      neurologic problem, but wanted to rule out peripheral
	      neuropathy and any systemic conditions with blood
	      work and and EMG.

	 102) On July 28, 1995 Bellamente had blood drawn for the
	      tests ordered by Dr. Adams.

	 103) On July 31, 1995, after three phone calls, Savastano
	      returned Hammel's call.  He questioned the complete
	      termination of benefits letter defying the medical IME.
	      Savastano told him not to worry, it was just a formality,
	      and that it didn't mean anything.  Hammel relied upon
	      this statement to his detriment.

	 104) On August 4, 1995 Bellamente presented himself to
	      Seymour Jotkowitz, M.D, a neurologist, for and EMG
	      study requested by Dr. Adams, which revealed "evidence
	      of cervical radiculopathy."

	 105) On August 4, 1995 Bellamente's blood work report was
	      written, which showed no signs of systemic neuropathy.

	 106) On August 17, 1995 Bellamente consulted with John F.
	      Pojedinec, M.D, an orthopaedic surgeon in Hackensack,
	      NJ on referral by Dr. Adams.

	 107) On or about August 17, 1995 Bellamente consulted with
	      Robert C. Rubin, M.D., a neurosurgeon in Hackensack, NJ.

	 108) Both Drs. Rubin and Pojedinec recommended that Bellamente
	      undergo C5-C6 disectomy and fusion to be performed at
	      Hackensack Hospital as soon as possible.

	 109) On September 7, 1995, being completely exhausted by
	      having to run businesses while in severe pain, and
	      having to deal with SFI, both Plaintiffs retired to
	      North Carolina for a brief respite before returning
	      for Bellamente's cervical surgery.

	 110) On September 14, 1995, Plaintiffs returned to N.J.,
	      to prepare for Plaintiff Bellamente's impending surgery.

	 111) On or about September 16, 1995, Plaintiff Bellamente
	      received two letters from Veronica Wade of SFI, one
	      terminating his Psychiatric Benefits, and the other
	      terminating his Neurological benefits, enclosing the
	      IME reports of Wagle and Fremed.  It was clear to
	      plaintiffs that SFI had quite literally sought and then
	      used the reports of Wagle and Fremed to terminate
	      Bellamente's psychiatric and neurological benefits, the
	      latter to cause the planned cervical surgery to be cancelled.

	 112) Upon reading the outrageous reports of Wagle and Fremed,
	      Plaintiffs became instantly aware that there was a deliberate
	      scheme of robbery, deceit and trickery being practiced by
	      Defendant SFI, with the sole purpose being to deny Plaintiffs
	      the personal injury treatment benefits to which they were
	      entitled, in order that Defendant SFI might keep to itself
	      money that it would have had to pay for Plaintiff's necessary
	      medical treatments, i.e.,  that SFI was implacably set on
	      a course  of "Unjust Enrichment" and "Unlawful Profit".

	 113) In September, 1995, it was SFI's institutional policy to
	      terminate benefits to all it's PIP insureds, arbitrarily,
	      by a "report" system which used the last treatment date
	      recommended in IME reports as the "term" date".

	 114) SFI failed, fairly, to investigate the basis upon which
	      Bellamente's claims were asserted, but instead conspired
	      to seek, and then conspired with Wagle and Fremed, for the
	      production of fraudulent IME reports whose sole purpose
	      was an excuse for the wrongful denial of both psychiatric
	      and neurological benefits, although the medical necessity
	      of both as a result of the MVA was clear to SFI.

	 115) These actions by SFI and its co-conspirators, effectively
	      and wrongfully terminated all of Plaintiff Bellamente's
	      PIP benefits, SFI having sought to eliminate Bellamente's
	      access to his chiropractor by refusing to pay for any
	      treatments by Dr. Boulukos after November 10, 1994, while
	      never informing Plaintiff Bellamente of any such
	      termination of benefits.

	 116) In the deliberate scheme to defraud and rob, Defendants
	      SFI conspired with other defendants, Melli, Wagle,
	      Psychiatric Associates, Rabin, and Fremed, and
	      specifically targeted Plaintiffs.
  
	 117) Plaintiffs relied on the fraudulently sold policy, much
	      to their detriment.

	 118) Plaintiffs relied, to their detriment, on Savastano's
	      telephone call, which she claimed Plaintiff Hammel's denial
	      letter didn't mean what it said, that it was a formality,
	      and not to worry.

	 119) On or about a time shortly preceding Plaintiffs' fraudulent
	      denial of PIP benefits, a scheme, at that time unknown to
	      Plaintiffs, there had been instituted by SFI to
	      "deny all claims", thus summarily defrauding policy
	      holders with meritorious claims, Plaintiffs being among
	      these.  This scheme was communicated by Matthews to
	      Savastano.

	 120) The mails were used in furtherance of this scheme.

	 121) Both phone and FAX were used in furtherance of this scheme.

	 122) Both Plaintiffs relied, with reasonable expectation, on
	      all the communications by wire and by mail, of their insurer
	      SFI up to a point of time, when the pattern of fraud
	      became recognized incontrovertibly, contradicting
	      Plaintiffs' belief that they were legitimately insured.
	      This prior reliance was to their detriment.

	 123) Plaintiffs relied to their detriment on the Fraudulent IME
	      of Bellamente by Wagle.

	 124) Plaintiffs relied to their detriment on the Fraudulent IME
	      of Bellamente by Fremed.

	 125) From September 14, 1995 on,  Plaintiffs businesses began to
	      fail, to the point of their not being able to pay bills.

	 126) From September 14, 1995 on, Plaintiffs health worsened
	      to the point of scarcely being able to work at all.

         127) From the plenary denial of all medical benefits to
	      Plaintiff Hammel on July 27, 1995, Savastano's comment
	      to the contrary notwithstanding, no action was taken on
	      Hammel's claim.  No request was made by defendant SFI for
	      a third IME until the request for an IME in a letter from
	      Idiana Murray of Defendant SFI dated September 21, 1995,
	      52 days later, wherein Hammel was 'asked' to call Dr.
	      Harry Merliss.

	 128) Plaintiff Hammel did, indeed, call and arrange an appointment
	      with Harry Merliss.  Thereafter, he investigated Dr. Merliss'
	      reputation, and found him to be notorious in the medical and
	      legal community for consistently prostituting himself for
	      the insurance industry.

	 129) Upon obtaining that knowledge, which was consistent
	      from several sources, Plaintiff Hammel cancelled
	      that appointment, and so informed Idiana Murray.

         130) Both Plaintiffs declined to be examined by Dr. Merliss,
	      then knowing full well what the conclusions would be.
	      Investigation of Merliss had made it very clear that SFI had
	      decided, in its pattern of fraud, robbery and deceit,
	      that no matter what, they would continue deny Plaintiffs
	      claims.

	 131) On November 5, 1995, a letter was sent by Plaintiff Hammel
	      to Murray by Certified mail, declining Merliss and demanding
	      that these unlawful denials be stopped. In that letter,
	      Hammel carefully explained how the termination of benefits,
	      given the IME reports, was unlawful.  This letter also put SFI
	      on notice that there would be great detriment to both plaintiffs
	      if this unlawful behavior of SFI persisted.

	      At this point, it became absolutely clear that both Plaintiffs
	      were going to be denied no matter what; if State Farm
	      persisted in its patterns and schemes of unlawful
	      activities, those very activities would be the direct
	      and proximate cause of serious further business and physical
	      damages, which would proceed inexorably.

  	 132) On October 18, 1995, Dr. Peter H. Schmaus wrote to Idiana
	      Murray, of Defendant SFI stating that he was
	      treating Plaintiff Hammel for injuries incurred in the MVA
	      of September 16, 1994, and that Hammel needed additional
	      treatments.

         133) On October 23, 1995, Dr. Robert C. Rubin wrote to Idiana
	      Murray, employee of Defendant SFI, stating that Plaintiff
	      Bellamente had one and possibly two disc herniations, which
	      he believed were caused by the MVA of September 16, 1994,
	      and requested that SFI authorize treatment for Bellamente.

	 134) On November 10, 1995, Dr John F. Pojedinec wrote to Idiana
	      Murray, employee of Defendant SFI, refuting Dr. Fremed's
	      IME report of Plaintiff Bellamente, on the basis of objective
	      testing which had been performed, concluding the substance of
	      his letter with, "...this patient's cervical
	      myeloradiculopathy is indeed present, is genuine and is the
	      result of his motor vehicle accident on September 16, 1994."

	 135) On October 31, 1995, Martin A. Kluger, Ph.D., Plaintiff
	      Bellamente's psychotherapist, wrote to Defendant SFI,
	      refuting the Wagle report, pointing out its inaccuracies,
	      based on his continuing observation and treatment of the
	      Plaintiff.  

	 136) Defendant SFI, persisting in its patterns of racketeering
	      activities, completely ignored the comments of these
	      respected physicians and adamantly refused to reconsider
	      its fraudulent denials.  

	 137) SFI failed, fairly, to investigate the basis upon which
	      the claims were asserted, but instead adhered to their
	      wrongful denial of benefits.

	 138) During this period, after SFI's wrongful denials, some of
	      Plaintiffs' healthcare givers continued to treat them,
	      without payment, most particularly Drs. Boulukos, Schmaus
	      and Kluger.

	 139) Some of the necessary medical treatments needed by
	      Plaintiffs were unavailable to them because of their
	      inability to pay for them.

         140) 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), whose existence was not present
	      on examination by Dr. Sender for similar symptoms on
	      October 30, 1995.

	 141) There is no medical explanation possible for the sudden
	      and coincident appearance of the LBBB, except the hormonal
	      chemistry of the intolerable stress level placed directly
	      upon this Plaintiff by Defendants.

         142) On or about December 4, 1995 Plaintiff Hammel submitted
	      two complaints to the New Jersey Department of Insurance
	      Consumer Complaints, (NJDICC), one on behalf of Plaintiff
	      Bellamente, and one on behalf of himself. Those are submitted
	      herewith as Exhibits A and B.

	 143) Exhibits A and B outline, in detail, Plaintiffs'
	      exposure, as it was then known, to the schemes and
	      patterns of fraud and robbery of Defendant SFI.

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

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

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

         147) 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.

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

         149) No answer, substantive affirmation or denial of any
              statement in Exhibits A and B were ever received from
              Defendants, by Plaintiffs.

         150) No answer, substantive affirmation or denial of any
              statement in Exhibits A and B were ever received from
              NJDICC, by Plaintiffs.

         151) 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.

	 152) Plaintiffs now have documents showing that Defendant, SFI
	      forwarded to Mr. Only, medical documents inappropriate to
	      the September 16, 1994 accident, but rather appropriate
	      to the 1992 accident with regard to Plaintiff
	      Bellamente, and dismissed Plaintiff Hammel's claim with
	      half-truths and unfounded conclusory statements.  It now
	      appears that Mr. Only did attempt a genuine investigation,
	      but was thwarted by Defendant SFI's continuing pattern of
	      racketeering activities.

         153) On or about January 4, 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."

         154) The conversation with Matthews was pleasant, and
	      Plaintiff Hammel regarded this, finally, as an act of
	      good faith, and later made it clear by FAX to SFI offices
	      that he would only deal with her.  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. Andronico, for
	      Bellamente.

	 155) An IME request letter naming Dr. John Andronico
	      arrived, dated January 4, 1996 for Plaintiff Hammel;
	      this is not what was agreed to.  Hammel had never been
	      able to see a neurologist or a neurosurgeon of his own
	      choice, and the policy does not provide for arbitrary
	      examinations; it provides for "Independent Medical
	      Examinations", which can hardly be considered truly
	      "Independent", since Defendant SFI, at that time,
	      maintained, as part of its scheme to deny claims and
	      defraud its customers, which was central to its pattern
	      of racketeering activities, a "list of approved physicians"
	      from which it drew physicians to conduct its IMEs, ensuring
	      its desired fraudulent reports, which it could use to deny
	      meritorious claims, in furtherance of its patterns of
	      racketeering activities.

	 156) An IME request letter naming Dr. John Andronico
	      arrived, dated January 4, 1996 for Plaintiff Bellamente
	      along with IME demands with two other physicians; an
	      Alexander Mittleman, M.D., for an orthopaedic IME, and
	      a David Gallina, for a psychological IME.  This was not
	      what was agreed to.  The plot was clear: SFI, through its
	      patterns of racketeering activities, would brook no
	      interference in its effort to obtain an excuse for denial
	      continuation.  It was only much later, in depositions of
	      Savastano and Murray, that Plaintiffs became aware that
	      Matthews was, in fact, the person who ordered the denials
	      from the beginning.  

         157) After telephone conversation with 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 an appointment by his office staff saying that,
              "State Farm does not pay it's bills."

         158) 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 Matthews, on or about January 18, 1996

         159) 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 to Linda Matthews,
              with a covering letter quoting the response from
              Dr. Andronico's office regarding IMEs for Defendants.

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

         161) No further requests for IMEs have since come from Defendant
	      SFI, although Plaintiff's have recently obtained documents
	      showing that SFI had transferred their file to Defendant SFM,
	      first in Asheville, North Carolina, then to Franklin, North
	      Carolina, where a Jim Zitney hired a "vendor", "Intracorp",
	      to arrange IMEs of the Plaintiffs.  According to those
	      documents, the IME's which Jim Zitney's vendor had arranged
	      were hastily cancelled when Plaintiffs attorneys filed PIP
	      suits, on their behalf, in New Jersey.

         162) 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.

         163) The single remaining store continued to founder due to
	      repeated closures because of Plaintiffs' incapacity
	      or appointments for medical treatment.

         164) In November, 1995, foreclosure on residence was clearly
	      inescapable.

         165) After several attempts to sell the video business, in
	      December, 1995, a bona fide buyer, Kenneth Kiley of
	      Ridgefield Park, offered to purchase it, and was in
	      the process of finalizing his arrangements, while
	      simultaneously being trained in the operation of
	      the business.

         166) On or about February 1, 1996, Plaintiffs, in severely
	      deteriorated physical and mental condition, placed all
	      their pending legal matters, including the sale of Ultra
	      Videos to Kenneth Kiley, in the hands of their long time
	      friend, John C. Gavejian, whom Plaintiffs named as their
	      replacement attorney.

         167) Plaintiffs informed Mr. Gavejian of their oral agreement
	      with Andreas Michael, of Teaneck, N.J., the landlord of
	      the premises of Ultra Videos, and Kenneth Kiley, wherein
	      Plaintiffs agreed that Mr. Gavejian was to pay back-rent
	      due on the premises to Mr. Michael from the proceeds of
	      the sale.

         168) On or about February 9, 1996, knowing of Plaintiffs'
	      conditions, Andreas Michael the landlord of the video
	      store "Ultra Videos" 288 Teaneck Road in Ridgefield
	      Park, N.J., despite his oral agreement with Plaintiffs,
	      had the premises sealed by the Sheriff, for back rent.

         169) The rent owed was considerably less than the value of
	      the contents of the store.  Plaintiffs were, illegally,
	      forbidden entry and lost valuable personal effects,
	      personal and financial records, as well as the
	      business itself.

         170) 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.

         171) To aid Plaintiffs in relocating, their long time friend,
	      Donald Walton, loaned them approximately $15,000., which
	      plaintiffs have yet to be able to repay.

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

         173) On or about November 20, 1995, Mountain Movers of Sylva,
	      North Carolina was hired for the move of Plaintiffs'
	      household items from New Jersey to North Carolina, at a
	      fee of approximately $6,000.  Despite receiving a most
	      complete inventory, Mountain Movers failed to move one (1)
	      out of four (4) floors of valuable personal effects.
	      All those items were lost, among them all Plaintiffs'
	      financial records.

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

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

	 176) Since, among the items lost was the signed contract
	      for the move from New Jersey to North Carolina,
	      Plaintiff's were unable to recover damages from
	      Mountain Movers.

         177) Plaintiff Bellamente was an owner of the house in which
              both Plaintiffs lived, while Plaintiff Hammel paid rent,
              he had also contributed approximately $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 on April 29, 1996, after
	      the move to North Carolina,

         178) 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.

         179) For some still unknown reason, Mr. Gavejian did not
              file a PIP suit, and became uncommunicative and
              unavailable, and never did file the requisite actions
	      against the tortfeasor Hukkanen or SFI.

	 180) On or about March 28, 1996, Defendant SFI, through
	      Idiana Murray, conspired with SFM, through Jim Zitney,
	      in furtherance and expansion of its wrongful scheme to
	      defraud and rob Plaintiffs of PIP benefits to which they
	      were rightfully entitled.

	 181) Defendant SFM's records indicate, quite mendaciously,
	      that the Insureds wanted the claim handled in Franklin.
	      Plaintiff's not only never made such request, they were
	      under the impression that SFI was their insurer, and only
	      did business in New Jersey, and knew of no State Farm
	      offices in Franklin, N.C.

	 182) On or about April 4, 1996, SFM, through Jim Zitney,
	      agreed to participate in the conspiracy to defraud and rob
	      Plaintiffs, by communicating with Murray "Please fill
	      me in on what I need to know...I guess I'm waiting for
	      your contents."

	 183) Before or about May 8, 1996, in furtherance of its
	      schemes of fraud and robbery, Idiana Murray
	      of SFI sent to Jim Zitney of SFM, certain medical
	      reports which were related to Plaintiff Bellamente's
	      August 6, 1992 MVA, ostensibly in connection with the
	      September 16, 1994 MVA.

	 184) On or about May 8, 1996, Jim Zitney of SFM perpetuates
	      the schemes of fraud and robbery by communicating to
	      Idiana Murray of SFI "Per my superintendent, I am awaiting
	      your direction to pay or deny payment for the recently
	      submitted chiropractic bills."

	 185) On or about May 21, 1996, SFM, through Jim Zitney,
	      acted on the conspiracy between SFI and SFM to continue
	      their schemes of fraud and robbery, by sending, from
	      SFM's Franklin N.C. office, letters, via certified mail,
	      to both Plaintiffs, once again, denying benefits.

	 186) Both SFI and SFM failed, fairly, to investigate the
	      basis upon which the claims were asserted, but instead
	      responded with yet another fraudulent denial of benefits,
	      based on their schemes of fraud and robbery.

	 187) On or about June 20, 1996, SFM through Jim Zitney,
	      made clear that the conspiracy to defraud Plaintiffs
	      included the Asheville office of SFM, through one
	      David Allen Swann, and that their acts, in furtherance
	      of their fraud and robbery included interfering with
	      the investigation of Plaintiffs complaint against SFI/SFM,
	      to the North Carolina Department of Insurance,
	      of May 29, 1996.

	 188) On or about August 21, 1996, documents indicate that
	      the subsidiary, SFI, is clearly directing the schemes of
	      fraud and robbery for its parent, SFM, by Sandra
	      Romei of SFI communicating to Jim Zitney of SFM: "At any
	      rate, you wanted some directives as to how you should be
	      proceeding on this file"; "We realize that Mr. Hammel and
	      Mr. Bellamente are difficult to deal with and frequently
	      complain to the Insurance Department"; "The examinations
	      that should be rescheduled are: Allan [sic] Bellamente
	      (remember he fell down the stairs)...William Hammel...Psych
	      is needed if now treating.  No exam or term in file." 

	      In this same communication, after commenting on the
	      "minor damage to the car", Romei tells Zitney: "I
	      suggest that you ask the current treating physicians
	      how the current treatment is related to this automobile
	      accident.  Then you can send their statements to the
	      examining physicians along with the prior reports and
	      car photos in order to obtain an impartial opinion.";
	      "If the doctors agree that the treatment is not related
	      to the motor vehicle accident, we should maintain our
	      original termination dates."; and finally, "Aside from
	      the above, we suggest that you use good claim handling
	      practices to control this claim."

	 189) In paragraph 188) above, note that Zitney had already sent
	      denial letters to both plaintiffs, clearly demonstrating
	      that SFM failed, fairly, to investigate the basis upon
	      which the claims were asserted, but instead responded with
	      yet another wrongful denial of benefits, based on their
	      schemes of fraud and robbery.

         190) On or about the 25th of May, 1996, response from the
	      New Jersey Department of Insurance was received by
	      Plaintiffs. That response amounted to a reiteration of
	      State Farm's litany of fraudulent excuses for denying
	      Plaintiff Bellamente's claims while ignoring Plaintiff
	      Hammel's situation completely.

         191) On or about May 29, 1996, Senator Byron Baer also sent a copy
	      of the "disappointing response" he had received from
	      Insurance Commissioner, Elizabeth Randall to Plaintiff Hammel,
	      noting in his letter that Randall's letter "does not address
	      your personal claim." (See Exhibit D)

         192) In further correspondence with Senator Baer, the
              Senator agreed that this was not, in fact, a report.
	      (See Exhibit D)

	 193) On May 29, 1996, Plaintiff Hammel filed a complaint
	      against both Defendants SFI and SFM with James E. Long,
	      Commissioner of Insurance of the State of North Carolina,
	      clearly demonstrating the fraud and tortious breach of
	      contract as well as indicating schemes of fraud and robbery by
	      defendants SFI and SFM in the State of North Carolina.

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

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

         196) 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 for excellence.

         197) In order to conserve Plaintiffs' energy and finances as
              much as possible, Plaintiffs arranged to see Dr. Haglund
	      at DUMC, on the way back to North Carolina, after having
	      met with Mr. Jackson, on August 22, 1996.

	 198) Plaintiffs saw Dr. Haglund, at the Duke University Medical
	      Center Private Diagnostic Surgical Clinic on August 26,
	      1996.  At that evaluation, Dr. Haglund recommended that
	      Plaintiff Hammel undergo surgery for decompression of his
	      cervical spinal cord as soon as possible, and that Plaintiff
	      Bellamente undergo disectomy and fusion only after Plaintiff
	      Hammel had recovered, since Hammel's condition was more
	      precarious than Bellamente's, at that time.

         199) At the evaluation of August 26, 1996, Plaintiff Hammel's
	      surgery was scheduled for September 18, 1996, but had
	      to be postponed a week, to September 25, 1996 because
	      of a hurricane.

	 200) On or about August 29, 1996, Hammel's action against SFI
	      was filed in Bergen County, New Jersey.

	 201) On September 3, 1996, Bellamente's action against SFI
	      as "State Farm Insurance  Company" was filed in Bergen
	      County, New Jersey.

	 202) On August 6, 1998, almost three years later, and more
	      than two years after SFI conspired with SFM in furtherance
	      and expansion of its scheme to defraud Plaintiffs by their
	      patterns of racketeering activities, and SFM had acted on
	      that conspiracy, to continue SFI's fraudulent denials,
	      Plaintiff Bellamente's attorney received a letter from
	      Donna Miller of Melli, who had originally announced that
	      Melli was engaged to represent "Defendant State Farm
	      Insurance Company", telling Plaintiff's attorney that
	      the proper party to have been named was "State Farm
	      Indemnity Company".

         203) 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 SFI, through Idiana Murray, and SFM, through
	      Jim Zitney, stood, recklessly, on their unwarranted denial
	      again saying, "the case is closed", in continuation of
	      their patterns of racketeering activities.

              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.

	 204) Both SFI and SFM failed, fairly, to investigate the
	      basis upon which the claims were asserted, but instead
	      responded with yet another wrongful denial of benefits,
	      based on their schemes of fraud and robbery.

         205) Both Plaintiffs applied for SSI benefits because of
              their 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.

         206) Plaintiffs' surgeries were rescheduled under Medicaid:
	      Plaintiff Hammel's on  May 13, 1997, and Plaintiff Bellamente's
	      on June 24, 1997. Both procedures were performed by Dr.
	      Michael M. Haglund, on those dates.

	 207) On or about November 6, 1996, Paul J. Jackson, attorney for
	      Plaintiff Hammel in the New Jersey actions, filed an Order to
	      Show Cause on behalf of Plaintiff in an attempt to get him
	      the necessary surgery.

	 208) On December 3, 1996, acting on advice of Defendant SFI's
	      attorney, Donna Miller, Jim Zitney of SFM, in Franklin,
	      N.C., signed and returned to Miller a Certification in
	      Opposition to Plaintiff's Application, written and
	      transmitted to him by Donna Miller.

	 209) This "Certification", carefully and artfully crafted by
	      Donna Miller, for Mr. Zitney's signature, and which he
	      signed, omitted significant details and information which
	      were in the possession of Miller at the time she crafted
	      the document.  Mr. Zitney's Certification was presented
	      to the Court in New Jersey, in furtherance of SFI's and
	      SFM's, now coordinated, racketeering activities.  According
	      to Mr. Zitney's notes, he was obviously troubled by the
	      final clause, which reads "I am subject to punishment."

         210) 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.

         211) 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 pain and dysesthesias which originate from the
              atrophied cord.  It has been partially effective and
	      is a presrcritible substance that will be required by
	      Plaintiff Hammel, for the rest of his life.

         212) While in New Jersey for depositions, Plaintiff Hammel
              was also 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 since,
              range of motion and pain of the Right Shoulder has not
              improved enduringly.

         213) 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, because
	      effects of damage to the cervical spinal cord have
	      compromised every body part and function at, and below,
	      the level of the cervical cord atrophy.  

	 214) Defendant SFI continually thwarted Plaintiffs' attorneys in
	      their attempts to take depositions of certain SFI employees,
	      to the extent that Plaintiff's attorneys had to file an
	      Order Compelling Depositions of SFI's employees.

	 215) Romei's deposition was cancelled many times, and she is
	      a key person in maintaining Defendants' fraudulent
	      denial of Plaintiffs' claims.  Romei never was produced
	      by SFI for deposition.

	 216) Defendant SFI continually thwarted Plaintiffs' attorneys
	      in their attempts to obtain documents and reports, under
	      the Rules of Discovery, to the point of not providing
	      certain documents until the very day of the Court Ordered
	      depositions of SFI's employees.

	 217) On July 15, 1998, Defendant SFI, by providing, literally,
	      reams of documents just one half hour prior to the
	      scheduled depositions, all of which should have been
	      provided to Plaintiffs' attorneys previously, materially
	      interfered with Plaintiffs' attorney's abilities to conduct
	      as thorough a deposition as would have been possible had
	      those Plaintiffs' attorneys had the documents according
	      to the Rules of Discovery.

	 218) On November 13, 1998 Donna Miller of Melli received notice
	      dated November 11, 1998, from Jackie Chadwick of SFI, that
	      "We have received authority to settle this suit [PIP];
	      kindly solicit an offer from plaintiffs' counsel and advise."	

	 219) On November 19, 1998, Wall, of Melli, wrote to Plaintiff's
	      attorneys, announcing that she was replacing Donna Miller
	      in the matters, and requesting that the attorneys: "provide
	      me with settlement demands so that we can begin discussions
	      toward resolving these matters."

	 220) On January 5, 1999, Defendant Eric L. Fremed, M.D. wrote a
	      "Paper Review" of selected documents, provided to him by
	      Defendant Melli, through Wall, of Plaintiff Bellamente, and
	      sent it to Wall.  At some time unknown to Plaintiffs this
	      review was sent to both Plaintiffs' attorneys.

	 221) On March 31, 1999, Defendant SFI issued checks to the
	      Department of Medical Assistance, in North Carolina,
	      covering that part of Plaintiff's treatments which the
	      Department, at that time, wished reimbursed.

	 222) On April 14, 1999, Defendant SFI issued checks to some of
	      those of Plaintiffs' healthcare givers whom it had
	      previously refused to pay.

	 223) On April 23, 1999, Wall sent checks and explanations of
	      benefits for Plaintiffs' healthcare givers, to Plaintiffs
	      attorneys, for distribution to those healthcare givers.

	 224) On or about May 8, 1999, Plaintiff Bellamente's chronic
	      lumbar pain, from which he has suffered since the MVA of
	      September 16, 1994, became acute.

	 225) On May 17, 1999, Plaintiff Hammel signed a release in the
	      PIP action in New Jersey.

	 226) Since May 17, 1999, when Plaintiff Hammel signed a release
	      in the PIP action in New Jersey, which calls for payment
	      of out of pocket expenses, no such payments have been paid
	      though the appropriate bills were submitted long ago; several
	      of them have been submitted repeatedly and have been ignored.

	 227) On or about June 4, 1999, despite as much bed rest as
	      practicable, Plaintiff Bellamente's lumbar problem worsened
	      severely, and at the earliest possible time, June 7, 1999,
	      he sought treatment.  After ruling out epidydimitis, an MRI
	      was prescribed.

	 228) On June 12, 1999 an MRI of Bellamente's lumbar spine was
	      made which revealed a herniated disc at L1-2.  That MRI
	      was immediately forwarded to Dr. Haglund at Duke University
	      Medical Center, since Dr Haglund was out of the country,
	      surgery was scheduled for August 17, 1999, the first
	      available time.

	 229) On June 14, 1999, Defendant Eric L. Fremed, M.D. wrote
	      another "Paper Review" of selected documents, provided
	      to him by Defendant Melli, through Wall, of Plaintiff
	      Bellamente, and sent it to Wall.  This review was sent
	      on June 29, 1999, to both Plaintiffs' attorneys to amend
	      Defendant's answers to interrogatories and specifying
	      Fremed as an "expert witness" to testify on his review
	      at the time of the UIM arbitration.  This amendment was
	      claimed not be an adoptive admission.  It was also sent
	      to the UIM Panel members with no claim that it was
	      "not to be deemed an adoptive admission", and is therefore
	      submitting the review to the panel as true.  On December
	      23, 1999, Dr. Fremed submitted yet a third paper review
	      on Plaintiff Bellamente.

	 230) On June 21, 1999, Plaintiff Bellamente signed a release
	      in the PIP action in New Jersey.

	 231) On June 30, 1999, Defendant Eric L. Fremed, M.D. wrote a
	      "Paper Review" of selected documents, provided to him by
	      Defendant Melli, through Wall, of Plaintiff Hammel, and
	      sent it to Wall.

	 232) On or about August 2, 1999, Defendant Melli, through Wall,
	      submitted Defendant Fremed's Review of Plaintiff Hammel
	      to the UIM arbitration panel, in N.J., and to both
	      Plaintiffs' attorneys to amend Defendant's answers to
	      interrogatories and specifying Fremed as an "expert
	      witness" to testify on his review at the time of the
	      UIM arbitration.  This amendment was claimed not be an
	      adoptive admission.  It was also sent to the UIM Panel
	      members with no claim that it was "not to be deemed an
	      adoptive admission", and is therefore submitting the
	      review to the panel as true.

	 233) On August 17, 1999, Plaintiff Bellamente underwent surgery
	      at DUMC, performed by Dr. Michael M. Haglund, for a
	      hemidisectomy.

	 234) On October 4, 1999, Plaintiff Hammel was diagnosed by Daniel
	      M. Eichenbaum, M.D. as having "Toxic Cataracts" and surgery
	      for removal of the more serious cataract was scheduled for
	      October 27, 1999.  Cataracts are a known possible side effect
	      of Neurontin.

	 235) a.
	      In or about Mid-October, 1999, Plaintiff Bellamente again
	      developed acute symptoms associated with the L1-L2 disc.
	      Dr. Haglund's Nurse Clinician, Sara Williams, arranged for
	      Bellamente to have an MRI done at District Memorial Hospital
	      in Andrews, N.C., and to have that MRI sent to Dr. Haglund,
	      at Duke. That MRI revealed additional disc material having
	      extruded from L1-L2, and surgery for its removal was to be
	      scheduled as soon as Dr. Haglund's schedule permitted.

	      b.
	      On October 27, 1999, Plaintiff Hammel underwent the first
	      surgery for toxic cataracts at Murphy Medical Center,
	      Murphy, N.C.; surgery was performed by Dr. Eichenbaum, who
	      replaced the natural lens of the right eye with a specially
	      designed plastic lens.  A similar surgery will be necessary
	      in the near future for left eye.

   ____________________________________________________________________

        IV. JURISDICTION


      236) 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 by Federal Statute and
	   by Diversity:

      237) Federal District court has jurisdiction over federal
	   questions, and by statute over

           a. 18 USC 1962(a)-(d)
           b. 18 USC 1964(c)
           c. 18 USC 1951

	   under 18 USC 1964(a), and also under

           d. 28 USC 1331
           e. 28 USC 1339

      238) 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 to the present time.

      239)

	   a. There is a diversity of citizenship since the
              Defendants Fremed, Rabin, Wagle, Psychiatric Associates,
	      and Melli are residents of New Jersey, while their actions
	      in the State Of New Jersey have interfered tortiously with
	      the finances and health of Plaintiffs who are residents of
	      the State of North Carolina.

	    b. SFI is a wholly owned subsidiary of SFM, and SFM does
	       business in many States of the United States; the home
	       offices of SFM are in the State of Illinois, of which it
	       is also a citizen, while SFI, upon information, belief
	       and reasonable investigation is licensed by the State
	       of New Jersey, and the State of Illinois to do business
	       within those, and possibly other States, and that it
	       does business only or primarily within the State of New
	       Jersey.

      240) 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
           Carolina; and further that other incorporated entities bearing
	   the name "State Farm" are incorporated subsidiaries wholy owned
	   by State Farm Mutual and are therefore controlled by State Farm
	   Mutual, and that the policies of claim handling in these entities
	   are the dictates of State Farm Mutual.  This is based on
	   information available in Best's.

      241) Based on the preceding, the allegations contained herein
           constitute a matter which affects Interstate Commerce, and
           also presents a condition of "diversity of citizenship"; the
           matter, therefore, falls within Federal Jurisdiction.

      242) 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 United States District Court,
	   Western District Court of North Carolina.

      243) Plaintiffs avail themselves of the law of the State of
	   North Carolina.

      244) 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.

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

   ____________________________________________________________________

        V. VENUE

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

        246) Plaintiffs reside, and have resided in Graham County,
             North Carolina for almost four (4) years; Graham
             County lies within the Federal Western District of
             North Carolina.  Venue regarding regarding all Defendants
	     is then pursuant to 18 USC 1965.

        247) The Parent company, SFM does business in the State of North
	     Carolina and has representatives in  The Western District
             of North Carolina.  Plaintiffs rely on 28 USC 1381(a)(2),
	     28 USC 1381(b)(3) and 28 USC 1381(c).

        248) 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 ends of justice.  This is not a matter of
	     convenience.

   ____________________________________________________________________

            VI. REFERENCE MEMORANDUM ON HOBBS APPLIED TO INSURERS

     249)  Plaintiffs here reference their Memorandum on the
	   Extortion Scheme and the Hobbs' Act, as attached
	   to this complaint.

   ____________________________________________________________________

           VII. CAUSES OF ACTION


			   FIRST CAUSE OF ACTION

	(Against Defendant SFI, for the intentional tort of

		                   FRAUD)

     250) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 52, 54, 64-66, 117.

     251) Defendant SFI has dealt unconscionably with Plaintiff
	  Bellamente in its unconscientious use of its power arising
	  out of its own relative position of superiority and resulting
	  in an unconscionable bargain that is the policy.

     252) In so doing, Defendant SFI has committed fraud.

     253) This primary fraud which has also lead to other torts through
	  which all Plaintiff Bellamente has been damaged in his business
	  property and person as set forth in section VIII of this
	  complaint and which is included here by reference in each and
	  every one of its paragraphs.

     254) WHEREFORE, Plaintiff demands judgment against the named
	  Defendant for actual damages to his business, property
	  and person; compensatory damages for pain, suffering
	  and extreme mental anguish resulting from the Defendant's
	  conduct; consequential damages for the foreseeable and
	  unforeseeable physical incapacitations and treatment of
	  medical sequelae; punitive and treble damages, in
	  consideration of the heedless, wanton, and oppressive,
	  malicious, and fraudulent conduct that Defendant SFI has
	  perpetrated on Plaintiff for a period beginning on or
	  about May 1, 1995 and continuing to the present.

     255) Plaintiff also demands judgment against the named
	  Defendant SFI for attorney fees, costs of suit and such
	  other relief as the Court deems just.


			   SECOND CAUSE OF ACTION

        (Against Defendant SFI, for the intentional tort of

	                          FRAUD)

     256) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 52, 54, 64-66, 117.

     257) Defendant SFI has dealt unconscionably with Plaintiff
	  Hammel in its unconscientious use of its power arising
	  out of its own relative position of superiority and resulting
	  in an unconscionable bargain that is the policy.

     258) In so doing, Defendant SFI has committed fraud.

     259) This primary fraud which has also lead to other torts through
	  which all, Plaintiff Hammel has been damaged in his business
	  property and person as set forth in section VIII of this
	  complaint and which is included here by reference in each and
	  every one of its paragraphs.

     260) WHEREFORE, Plaintiff demands judgment against the named
	  Defendant for actual damages to his business, property
	  and person; compensatory damages for pain, suffering
	  and extreme mental anguish resulting from the Defendant's
	  conduct; consequential damages for the foreseeable and
	  unforeseeable physical incapacitations and treatment of
	  medical sequelae; punitive and treble damages, in
	  consideration of the heedless, wanton, and oppressive,
	  malicious, and fraudulent conduct that Defendant SFI has
	  perpetrated on Plaintiff for a period beginning on or
	  about May 1, 1995 and continuing to the present.

     261) Plaintiff also demands judgment against the named
	  Defendant SFI for attorney fees, costs of suit and such
	  other relief as the Court deems just.


			   THIRD CAUSE OF ACTION

        (Against Defendant SFI, for the intentional tort of

		               FRAUD IN FACT)

     262) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 97 and 98.

     263) Defendant SFI through its employee Savastano sent a
	  termination letter to Plaintiff Hammel Dated July 27, 1995
	  denying all medical benefits, misrepresenting a second
	  IME report by saying that "in the doctor's opinion, no
	  further treatment was necessary."  When, in fact, no
	  thing was said, nor could such a conclusion be drawn.
	  The report, in fact, suggested further treatment.

     264) In so doing, Defendant SFI has committed a fraud in fact,
	  by eliminating and denying necessary medical treatment
	  that was, in fact, never allowed by SFI, and which has
	  lead to permanent damages to his business, property and
	  person as set forth in section VIII of this complaint and
	  which is included here by reference in each and every one of
	  its paragraphs.

     265) WHEREFORE, Plaintiff demands judgment against the named
	  Defendant for actual damages to his business, property
	  and person; compensatory damages for pain, suffering
	  and extreme mental anguish resulting from the Defendant's
	  conduct; consequential damages for the foreseeable and
	  unforeseeable physical incapacitations and treatment of
	  medical sequelae; punitive and treble damages, in
	  consideration of the heedless, wanton, and oppressive,
	  malicious, and fraudulent conduct that Defendant SFI has
	  perpetrated on Plaintiff for a period beginning on or
	  about May 1, 1995 and continuing to the present.

     266) Plaintiff also demands judgment against the named
	  Defendant SFI for attorney fees, costs of suit and such
	  other relief as the Court deems just.


			   FOURTH CAUSE OF ACTION

        (Against Defendant SFI, for the intentional tort of

		                   FRAUD)

     267) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 98, 99 103, 118.

     268) Defendant SFI through its employee Savastano denied that the
	  termination letter to Plaintiff Hammel Dated July 27, 1995
	  had any significance, and that there was cause for worry,
	  "that it did not mean what it says" and "was a formality".

     269) In so doing, Defendant SFI has committed a fraud, upon which
	  Plaintiff Hammel relied to his detriment by deferring necessary
	  medical treatment that was, in fact, never allowed by SFI,
	  and which has lead to permanent damages to his business,
	  property and person as set forth in section VIII of this
	  complaint and which is included here by reference in each and
	  every one of its paragraphs.

     270) WHEREFORE, Plaintiff demands judgment against the named
	  Defendant for actual damages to his business, property
	  and person; compensatory damages for pain, suffering
	  and extreme mental anguish resulting from the Defendant's
	  conduct; consequential damages for the foreseeable and
	  unforeseeable physical incapacitations and treatment of
	  medical sequelae; punitive and treble damages, in
	  consideration of the heedless, wanton, and oppressive,
	  malicious, and fraudulent conduct that Defendant SFI has
	  perpetrated on Plaintiff for a period beginning on or
	  about May 1, 1995 and continuing to the present.

     271) Plaintiff also demands judgment against the named
	  Defendant SFI for attorney fees, costs of suit and such
	  other relief as the Court deems just.


			   FIFTH CAUSE OF ACTION

        (Against Defendant SFI, for the intentional tort of

                              MALICIOUS FRAUD)

     272) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 92, 95 111-115.

     273) Defendant SFI through its employee Savastano sent to
	  Plaintiff Bellamente, through the mails, on June 8, 1995,
	  a demand for a psychiatric IME with a Dr. Sharad Wagle,
	  presenting this demand as an Independent Medical Examination,
	  and "Second Opinion" while knowing that a fraudulent
	  "examination" was to be performed, and that the resulting
	  report would be used as an excuse to terminate Bellamente's
	  psychiatric benefits.

     274) In so doing, Defendant SFI has committed a fraud, upon which
	  Plaintiff Bellamente relied, by attending the IME, to his
	  detriment by providing SFI with the fraudulent excuse it
	  wanted to terminate Plaintiff's psychological benefits,
	  and which has directly caused permanent damages to his
	  business, property and person as set forth in section VIII
	  of this complaint and which is included here by reference
	  in each and every one of its paragraphs.

     275) WHEREFORE, Plaintiff demands judgment against the named
	  Defendant for actual damages to his business, property
	  and person; compensatory damages for pain, suffering
	  and extreme mental anguish resulting from the Defendant's
	  conduct; consequential damages for the foreseeable and
	  unforeseeable physical incapacitations and treatment of
	  medical sequelae; punitive and treble damages, in
	  consideration of the heedless, wanton, and oppressive,
	  malicious, and fraudulent conduct that Defendant SFI has
	  perpetrated on Plaintiff for a period beginning on or
	  about May 1, 1995 and continuing to the present.

     276) Plaintiff also demands judgment against the named
	  Defendant SFI for attorney fees, costs of suit and such
	  other relief as the Court deems just.


			   SIXTH CAUSE OF ACTION

        (Against Defendant SFI, for the intentional tort of

	                      MALICIOUS FRAUD)

     277) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 92, 95 111-115.

     278) Defendant SFI through its employee Savastano sent to Plaintiff
	  Bellamente, through the mails, on June 8, 1995, a demand for
	  a neurological IME with a Dr. Eric L. Fremed, presenting this
	  demand as an Independent Medical Examination, and "Second
	  Opinion" while knowing that a fraudulent "examination" was to
	  be performed, and that the resulting report would be used as
	  an excuse to terminate Bellamente's neurologic benefits.

     279) In so doing, Defendant SFI has committed a fraud, upon which
	  Plaintiff Bellamente relied to his detriment by being forced
	  into deferring necessary medical treatment for damages caused
	  by the MVA that was, in fact, never allowed by SFI,
	  and which has directly caused permanent damages to his
	  business, property and person as set forth in section VIII
	  of this complaint and which is included here by reference in
	  each and every one of its paragraphs.

     280) WHEREFORE, Plaintiff demands judgment against the named
	  Defendant for actual damages to his business, property
	  and person; compensatory damages for pain, suffering
	  and extreme mental anguish resulting from the Defendant's
	  conduct; consequential damages for the foreseeable and
	  unforeseeable physical incapacitations and treatment of
	  medical sequelae; punitive and treble damages, in
	  consideration of the heedless, wanton, and oppressive,
	  malicious, and fraudulent conduct that Defendant SFI has
	  perpetrated on Plaintiff for a period beginning on or
	  about May 1, 1995 and continuing to the present.

     281) Plaintiff also demands judgment against the named
	  Defendant SFI for attorney fees, costs of suit and such
	  other relief as the Court deems just.


			   SEVENTH CAUSE OF ACTION

	(Against Defendants Wagle and Psychiatric Associates,
	 for the intentional tort of

		               MALICIOUS FRAUD)

     282) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 92, 95 111-115, 123, 135.

     283) Defendant Wagle presented to SFI as a valid and professionally
	  competent IME, his report, while knowing that is was a
	  sham and a fabrication, and also knowing the use to which
	  it would be put.

     284) In so doing, Defendants Wagle and Psychiatric Associates have
	  committed a malicious fraud, upon which Plaintiff Bellamente
	  relied to his detriment by deferring necessary medical
	  treatment that was, in fact, never allowed by SFI, and which
	  has lead to permanent damages to his business, property and
	  person as set forth in section VIII of this complaint and which
	  is included here by reference in each and every one of its
	  paragraphs.

     285) WHEREFORE, Plaintiff demands judgment against the named
	  Defendants for actual damages to his business, property
	  and person; compensatory damages for pain, suffering
	  and extreme mental anguish resulting from the Defendant's
	  conduct; consequential damages for the foreseeable and
	  unforeseeable physical incapacitations and treatment of
	  medical sequelae; punitive and treble damages, in
	  consideration of the heedless, wanton, and oppressive,
	  malicious, and fraudulent conduct that Defendants Wagle,
	  and Psychiatric Associates have perpetrated on Plaintiff
	  for a period beginning on or about May 1, 1995
	  and continuing to the present.

     286) Plaintiff also demands judgment against the named
	  Defendants Wagle, and Psychiatric associates for
	  attorney fees, costs of suit and such other relief
	  as the Court deems just.


			   EIGHTH CAUSE OF ACTION

        (Against Defendants Fremed and Rabin
	 for the intentional tort of

		               MALICIOUS FRAUD)

     287) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 92, 95 111-115.

     288) Plaintiffs refer to their Memorandum on Dr. Fremed's Report
	  and Reviews [Attachment 4] as Supplementary Allegements.

     289) Defendant Fremed presented to SFI as a valid and professionally
	  competent IME, his report, while knowing that is was a
	  sham and a fabrication, and also knowing the use to which
	  it would be put.

     290) In so doing, Defendants Fremed, and Rabin have
	  committed a malicious fraud, upon which Plaintiff Bellamente
	  relied to his detriment by deferring necessary
	  medical treatment that was, in fact, never allowed by SFI,
	  and which has lead to permanent damages to his business,
	  property and person as set forth in section VIII of this
	  complaint and which is included here by reference in each and
	  every one of its paragraphs.

     291) WHEREFORE, Plaintiff demands judgment against the named
	  Defendants for actual damages to his business, property
	  and person; compensatory damages for pain, suffering
	  and extreme mental anguish resulting from the Defendant's
	  conduct; consequential damages for the foreseeable and
	  unforeseeable physical incapacitations and treatment of
	  medical sequelae; punitive and treble damages, in
	  consideration of the heedless, wanton, and oppressive,
	  malicious, and fraudulent conduct that Defendants Fremed,
	  and Rabin have perpetrated on Plaintiff for a period
	  beginning on or about May 1, 1995 and continuing
	  to the present.

     292) Plaintiff also demands judgment against the named
	  Defendants Fremed, and Rabin for attorney fees, costs
	  of suit and such other relief as the Court deems just.


			   NINTH CAUSE OF ACTION

        (Against Defendants Fremed and Rabin
         for the intentional tort of

		               MALICIOUS FRAUD)

     293) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 220.

     294) Plaintiffs refer to their Memorandum on Dr. Fremed's Report
	  and Reviews [Attachment 4] as Supplementary Allegations.

     295) In a Paper Review dated January 5, 1999, Defendant Fremed
	  presented to SFI, through it attorney Wall of Melli as valid
	  and professionally competent, a Paper Review which was based
	  primarily on his prior fraudulent IME report, and summarily
	  dismissing the opinions and knowledge of all treating
	  healthcare givers, while knowing that it was a sham and a
	  fabrication, and knowing the use to which it would be put,
	  in particular knowing that the Review could be submitted
	  to the Superior Court of of New Jersey, and/or an arbitration
	  panel, an adjudicating body of the State of New Jersey.
	  The Review was submitted to the UIM arbitration panel.

     296) In so doing, Defendants Fremed, and Rabin have committed a
	  malicious fraud in fact, with knowledge and intent, foisting
	  intentional misrepresentations upon the Court, and upon
	  Plaintiff Bellamente in order to slander Plaintiff Bellamente's
	  meritorious claims under the policy, and to deny their merit,
	  and so to deny Plaintiff's claims, in the scheme to defraud,
	  causing damage to his business, property and person as set
	  forth in section VIII of this complaint and which is included
	  here by reference in each and every one of its paragraphs.

     297) WHEREFORE, Plaintiff demands judgment against the named
	  Defendants for actual damages to his business, property
	  and person; compensatory damages for pain, suffering
	  and extreme mental anguish resulting from the Defendant's
	  conduct; consequential damages for the foreseeable and
	  unforeseeable physical incapacitations and treatment of
	  medical sequelae; punitive and treble damages, in
	  consideration of the heedless, wanton, and oppressive,
	  malicious, and fraudulent conduct that Defendants Fremed
	  and Rabin have perpetrated on Plaintiff for a period
	  beginning on or about May 1, 1995 and continuing to
	  the present.

     298) Plaintiff also demands judgment against the named
	  Defendants Fremed and Rabin for attorney fees, costs of
	  suit and such other relief as the Court deems just.


			   TENTH CAUSE OF ACTION

	(Against Defendant SFI
	 for the intentional tort of

		               MALICIOUS FRAUD)

     299) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 220.

     300) Plaintiffs refer to their Memorandum on Dr. Fremed's Report
	  and Reviews [Attachment 4] as Supplementary Allegations.

     301) The Paper Review dated January 5, 1999, written by
	  Defendant Fremed, and requested by Wall of Melli was
	  presented by SFI through its attorneys Melli to both
	  Plaintiffs' attorneys, to amend Defendant's answers to
	  interrogatories as valid and professionally competent,
	  a Paper Review, while knowing that is was a sham and a
	  fabrication, and knowing the use to which it would be put,
	  in particular knowing that the Review could be submitted
	  to the Superior Court of of New Jersey, and/or an
	  arbitration panel, an adjudicating body of the State of
	  New Jersey.  The Review was submitted to the UIM arbitration
	  panel.

     302) In so doing, Defendant SFI has committed a malicious fraud
	  in fact with knowledge and intent, foisting intentional
	  misrepresentations upon the Court, and upon Plaintiff
	  Bellamente in order to slander Plaintiff Bellamente's
	  meritorious claims under the policy, and to deny their merit,
	  and so to deny Plaintiff's claims, in the scheme to defraud,
	  causing damage to his business, property and person as set
	  forth in section VIII of this complaint and which is included
	  here by reference in each and every one of its paragraphs.

     303) WHEREFORE, Plaintiff demands judgment against the named
	  Defendant for actual damages to his business, property
	  and person; compensatory damages for pain, suffering
	  and extreme mental anguish resulting from the Defendant's
	  conduct; consequential damages for the foreseeable and
	  unforeseeable physical incapacitations and treatment of
	  medical sequelae; punitive and treble damages, in
	  consideration of the heedless, wanton, and oppressive,
	  malicious, and fraudulent conduct that Defendant SFI has
	  perpetrated on Plaintiff for a period beginning on or
	  about May 1, 1995 and continuing to the present.

     304) Plaintiff also demands judgment against the named
	  Defendant SFI for attorney fees, costs of suit and such
	  other relief as the Court deems just.


			   ELEVENTH CAUSE OF ACTION

	(Against Defendant Melli
	 for the intentional tort of

		               MALICIOUS FRAUD)

     305) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 220.

     306) Plaintiffs refer to their Memorandum on Dr. Fremed's Report
	  and Reviews [Attachment 4] as Supplementary Allegations.

     307) The Paper Review dated January 5, 1999, written by
	  Defendant Fremed, and requested by Wall of Melli was
	  by Melli to both Plaintiffs' attorneys, to amend
	  Defendant's answers to interrogatories as valid and
	  professionally competent, a Paper Review, while knowing
	  and not making reasonable investigation, that is was a
	  sham and a fabrication, and knowing the use to which it
	  would be put, in particular knowing that the Review could
	  be submitted to the Superior Court of of New Jersey,
	  and/or an arbitration panel, an adjudicating body of the
	  State of New Jersey.  The Review was submitted to the UIM
	  arbitration panel.

     308) In so doing, Defendant Melli has committed a malicious fraud
	  in fact with knowledge and intent, foisting intentional
	  misrepresentations upon the Court, and upon Plaintiff Bellamente
	  in order to slander Plaintiff Bellamente's meritorious claims
	  under the policy, and to deny their merit, and so to deny
	  Plaintiff's claims, in the scheme to defraud, causing damage
	  to his business, property and person as set forth in section
	  VIII of this complaint and which is included here by reference
	  in each and every one of its paragraphs.

     309) WHEREFORE, Plaintiff demands judgment against the named
	  Defendant for actual damages to his business, property
	  and person; compensatory damages for pain, suffering
	  and extreme mental anguish resulting from the Defendant's
	  conduct; consequential damages for the foreseeable and
	  unforeseeable physical incapacitations and treatment of
	  medical sequelae; punitive and treble damages, in
	  consideration of the heedless, wanton, and oppressive,
	  malicious, and fraudulent conduct that Defendant Melli
	  has perpetrated on Plaintiff for a period beginning on
	  or about May 1, 1995 and continuing to the present.

     310) Plaintiff also demands judgment against the named
	  Defendant Melli for attorney fees, costs of suit and such
	  other relief as the Court deems just.


			   TWELFTH CAUSE OF ACTION

	(Against Defendants Fremed and Rabin
	 for the intentional tort of

		               MALICIOUS FRAUD)

     311) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 229.

     312) Plaintiffs refer to their Memorandum on Dr. Fremed's Report
	  and Reviews [Attachment 4] as Supplementary Allegations.

     313) In a Paper Review dated June 14, 1999, Defendant Fremed
	  presented to SFI, through it attorney Wall of Melli as valid
	  and professionally competent, a Paper Review which was based
	  primarily on his prior fraudulent IME report, and summarily
	  dismissing the opinions and knowledge of all treating
	  healthcare givers, while knowing that it was a sham and a
	  fabrication, and knowing the use to which it would be put,
	  in particular knowing that the Review could be submitted
	  to the Superior Court of of New Jersey, and/or an arbitration
	  panel, an adjudicating body of the State of New Jersey.
	  The Review was submitted to the UIM arbitration panel.

     314) In so doing, Defendants Fremed and Rabin have committed a
	  malicious fraud in fact, with knowledge and intent, violating
	  foisting intentional misrepresentations upon the Court, and
	  Plaintiff Bellamente in order to slander Plaintiff Bellamente's
	  meritorious claims under the policy, and to deny their merit,
	  and so to deny Plaintiff's claims, in the scheme to defraud,
	  causing damage to his business, property and person as set forth
	  in section VIII of this complaint and which is included here
	  by reference in each and every one of its paragraphs.

     315) WHEREFORE, Plaintiff demands judgment against the named
	  Defendants for actual damages to his business, property
	  and person; compensatory damages for pain, suffering
	  and extreme mental anguish resulting from the Defendant's
	  conduct; consequential damages for the foreseeable and
	  unforeseeable physical incapacitations and treatment of
	  medical sequelae; punitive and treble damages, in
	  consideration of the heedless, wanton, and oppressive,
	  malicious, and fraudulent conduct that Defendants Fremed
	  and Rabin have perpetrated on Plaintiff for a period
	  beginning on or about May 1, 1995 and continuing to
	  the present.

     316) Plaintiff also demands judgment against the named
	  Defendants Fremed and Rabin for attorney fees, costs of
	  suit and such other relief as the Court deems just.


			   THIRTEENTH CAUSE OF ACTION

	(Against Defendant SFI
	 for the intentional tort of

		               MALICIOUS FRAUD)

     317) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 229.

     318) Plaintiffs refer to their Memorandum on Dr. Fremed's Report
	  and Reviews [Attachment 4] as Supplementary Allegations.

     319) The Paper Review dated June 14, 1999, written by
	  Defendant Fremed, and requested by Wall of Melli was
	  presented by SFI through its attorneys Melli to both
	  Plaintiffs' attorneys, to amend Defendant's answers to
	  interrogatories as valid and professionally competent,
	  a Paper Review, while knowing that is was a sham and a
	  fabrication, and knowing the use to which it would be put,
	  in particular knowing that the Review could be submitted
	  to the Superior Court of of New Jersey, and/or an
	  arbitration panel, an adjudicating body of the State of
	  New Jersey.  The Review was submitted to the UIM arbitration
	  panel.

     320) In so doing, Defendant SFI has committed a malicious fraud
	  in fact with knowledge and intent, foisting intentional
	  misrepresentations upon the Court, and upon Plaintiff Bellamente
	  in order to slander Plaintiff Bellamente's meritorious claims
	  under the policy, and to deny their merit, and so to deny
	  Plaintiff's claims, in the scheme to defraud, causing damage
	  to his business, property and person as set forth in section
	  VIII of this complaint and which is included here by reference
	  in each and every one of its paragraphs.

     321) WHEREFORE, Plaintiff demands judgment against the named
	  Defendant for actual damages to his business, property
	  and person; compensatory damages for pain, suffering
	  and extreme mental anguish resulting from the Defendant's
	  conduct; consequential damages for the foreseeable and
	  unforeseeable physical incapacitations and treatment of
	  medical sequelae; punitive and treble damages, in
	  consideration of the heedless, wanton, and oppressive,
	  malicious, and fraudulent conduct that Defendant SFI has
	  perpetrated on Plaintiff for a period beginning on or
	  about May 1, 1995 and continuing to the present.

     322) Plaintiff also demands judgment against the named
	  Defendant SFI for attorney fees, costs of suit and such
	  other relief as the Court deems just.


			   FOURTEENTH CAUSE OF ACTION

	(Against Defendant Melli
	 for the intentional tort of

		                MALICIOUS FRAUD)

     323) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 229.

     324) Plaintiffs refer to their Memorandum on Dr. Fremed's Report
	  and Reviews [Attachment 4] as Supplementary Allegations.

     325) The Paper Review dated June 14, 1999, written by
	  Defendant Fremed, and requested by Wall of Melli was
	  presented by Melli to both Plaintiffs' attorneys, to amend
	  Defendant's answers to interrogatories as valid and
	  professionally competent, a Paper Review, while knowing
	  and not making reasonable investigation, that is was a
	  sham and a fabrication, and knowing the use to which it
	  would be put, in particular knowing that the Review could
	  be submitted to the Superior Court of of New Jersey,
	  and/or an arbitration panel, an adjudicating body of the
	  State of New Jersey.  The Review was submitted to the UIM
	  arbitration panel.

     326) In so doing, Defendant Melli has committed a malicious fraud
	  in fact with knowledge and intent, foisting intentional
	  misrepresentations upon the Court, and upon Plaintiff Bellamente
	  in order to slander Plaintiff Bellamente's meritorious claims
	  under the policy, and to deny their merit, and so to deny
	  Plaintiff's claims, in the scheme to defraud, causing damage
	  to his business, person and property, as set forth in section
	  VIII of this complaint and which is included here by reference
	  in each and every one of its paragraphs.

     327) WHEREFORE, Plaintiff demands judgment against the named
	  Defendant for actual damages to his business, property
	  and person; compensatory damages for pain, suffering
	  and extreme mental anguish resulting from the Defendant's
	  conduct; consequential damages for the foreseeable and
	  unforeseeable physical incapacitations and treatment of
	  medical sequelae; punitive and treble damages, in
	  consideration of the heedless, wanton, and oppressive,
	  malicious, and fraudulent conduct that Defendant Melli
	  has perpetrated on Plaintiff for a period beginning on
	  or about May 1, 1995 and continuing to the present.

     328) Plaintiff also demands judgment against the named
	  Defendant Melli for attorney fees, costs of suit and such
	  other relief as the Court deems just.


			   FIFTEENTH CAUSE OF ACTION

	(Against Defendants Fremed and Rabin
	 for the intentional tort of

	    	                MALICIOUS FRAUD)

     329) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 229.

     330) Plaintiffs refer to their Memorandum on Dr. Fremed's Report
	  and Reviews [Attachment 4] as Supplementary Allegations.

     331) In a Paper Review dated December 23, 1999, Defendant Fremed
	  presented to SFI, through it attorney Wall of Melli as valid
	  and professionally competent, a Paper Review which was based
	  primarily on his prior fraudulent IME report, and summarily
	  dismissing the opinions and knowledge of all treating
	  healthcare givers, while knowing that it was a sham and a
	  fabrication, and knowing the use to which it would be put,
	  in particular knowing that the Review could be submitted
	  to the Superior Court of of New Jersey, and/or an arbitration
	  panel, an adjudicating body of the State of New Jersey.
	  The Review was submitted to the UIM arbitration panel.

     332) In so doing, Defendants Fremed and Rabin have committed a
	  malicious fraud in fact, with knowledge and intent, foisting
	  intentional misrepresentations upon the Court, and upon
	  Plaintiff Bellamente in order to slander Plaintiff Bellamente's
	  meritorious claims under the policy, and to deny their merit,
	  and so to deny Plaintiff's claims, in the scheme to defraud,
	  causing damage to his business, person and property, as set
	  forth in section VIII of this complaint and which is included
	  here by reference in each and every one of its paragraphs.

     333) WHEREFORE, Plaintiff demands judgment against the named
	  Defendants for actual damages to his business, property
	  and person; compensatory damages for pain, suffering
	  and extreme mental anguish resulting from the Defendant's
	  conduct; consequential damages for the foreseeable and
	  unforeseeable physical incapacitations and treatment of
	  medical sequelae; punitive and treble damages, in
	  consideration of the heedless, wanton, and oppressive,
	  malicious, and fraudulent conduct that Defendants Fremed
	  and Rabin have perpetrated on Plaintiff for a period
	  beginning on or about May 1, 1995 and continuing to
	  the present.

     334) Plaintiff also demands judgment against the named
	  Defendants Fremed and Rabin for attorney fees, costs of
	  suit and such other relief as the Court deems just.


			   SIXTEENTH CAUSE OF ACTION

	(Against Defendant SFI
	 for the intentional tort of

		                MALICIOUS FRAUD)

     335) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 229.

     336) Plaintiffs refer to their Memorandum on Dr. Fremed's Report
	  and Reviews [Attachment 4] as Supplementary Allegations.

     337) The Paper Review dated December 23, 1999, written by
	  Defendant Fremed, and requested by Wall of Melli was
	  presented by SFI through its attorneys Melli to both
	  Plaintiffs' attorneys, to amend Defendant's answers to
	  interrogatories as valid and professionally competent,
	  a Paper Review, while knowing that is was a sham and a
	  fabrication, and knowing the use to which it would be put,
	  in particular knowing that the Review could be submitted
	  to the Superior Court of of New Jersey, and/or an
	  arbitration panel, an adjudicating body of the State of
	  New Jersey.  The Review was submitted to the UIM arbitration
	  panel.

     338) In so doing, Defendant SFI has committed a malicious fraud
	  in fact with knowledge and intent, foisting intentional
	  misrepresentations upon the Court, and upon Plaintiff Bellamente
	  in order to slander Plaintiff Bellamente's meritorious claims
	  under the policy, and to deny their merit, and so to deny
	  Plaintiff's claims, in the scheme to defraud, causing damage
	  to his business, person and property, as set forth in section
	  VIII of this complaint and which is included here by reference
	  in each and every one of its paragraphs.

     339) WHEREFORE, Plaintiff demands judgment against the named
	  Defendant for actual damages to his business, property
	  and person; compensatory damages for pain, suffering
	  and extreme mental anguish resulting from the Defendant's
	  conduct; consequential damages for the foreseeable and
	  unforeseeable physical incapacitations and treatment of
	  medical sequelae; punitive and treble damages, in
	  consideration of the heedless, wanton, and oppressive,
	  malicious, and fraudulent conduct that Defendant SFI has
	  perpetrated on Plaintiff for a period beginning on or
	  about May 1, 1995 and continuing to the present.

     340) Plaintiff also demands judgment against the named
	  Defendant SFI for attorney fees, costs of suit and such
	  other relief as the Court deems just.


			   SEVENTEENTH CAUSE OF ACTION

	(Against Defendant Melli
	 for the intentional tort of

		                 MALICIOUS FRAUD)

     341) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 229.

     342) Plaintiffs refer to their Memorandum on Dr. Fremed's Report
	  and Reviews [Attachment 4] as Supplementary Allegations.

     343) The Paper Review dated December 23, 1999, written by
	  Defendant Fremed, and requested by Wall of Melli was
	  by Melli to both Plaintiffs' attorneys, to amend
	  Defendant's answers to interrogatories as valid and
	  professionally competent, a Paper Review, while knowing
	  and not making reasonable investigation, that is was a
	  sham and a fabrication, and knowing the use to which it
	  would be put, in particular knowing that the Review could
	  be submitted to the Superior Court of of New Jersey,
	  and/or an arbitration panel, an adjudicating body of the
	  State of New Jersey.  The Review was submitted to the UIM
	  arbitration panel.

     344) In so doing, Defendant Melli has committed a malicious fraud
	  in fact with knowledge and intent, foisting intentional
	  misrepresentations upon the Court, and upon Plaintiff Bellamente
	  in order to slander Plaintiff Bellamente's meritorious claims
	  under the policy, and to deny their merit, and so to deny
	  Plaintiff's claims, in the scheme to defraud, causing damage
	  to his business, person and property, as set forth in section
	  VIII of this complaint and which is included here by reference
	  in each and every one of its paragraphs.

     345) WHEREFORE, Plaintiff demands judgment against the named
	  Defendant for actual damages to his business, property
	  and person; compensatory damages for pain, suffering
	  and extreme mental anguish resulting from the Defendant's
	  conduct; consequential damages for the foreseeable and
	  unforeseeable physical incapacitations and treatment of
	  medical sequelae; punitive and treble damages, in
	  consideration of the heedless, wanton, and oppressive,
	  malicious, and fraudulent conduct that Defendant Melli
	  has perpetrated on Plaintiff for a period beginning on
	  or about May 1, 1995 and continuing to the present.

     346) Plaintiff also demands judgment against the named
	  Defendant Melli for attorney fees, costs of suit and such
	  other relief as the Court deems just.


			   EIGHTEENTH CAUSE OF ACTION

	(Against Defendants Fremed and Rabin
	 for the intentional tort of

		                MALICIOUS FRAUD)

     347) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 232.

     348) Plaintiffs refer to their Memorandum on Dr. Fremed's Report
	  and Reviews [Attachment 4] as Supplementary Allegations.

     349) In a Paper Review of Plaintiff Hammel's medical records,
	  dated June 30, 1999, Defendant Fremed presented to SFI,
	  through it attorney Wall of Melli as valid and professionally
	  competent, summarily dismissing the opinions and knowledge of
	  all treating healthcare givers, while knowing that it was a
	  sham and a fabrication, and knowing the use to which it would
	  be put, in particular knowing that the Review could be
	  submitted to the Superior Court of of New Jersey, and/or an
	  arbitration panel, an adjudicating body of the State of New
	  Jersey.  The Review was submitted to the UIM arbitration panel.

     350) In so doing, Defendants Fremed and Rabin have committed a
	  malicious fraud in fact, with knowledge and intent, foisting
	  intentional misrepresentations upon the Court, and upon
	  Plaintiff Hammel in order to slander Plaintiff Hammel's
	  meritorious claims under the policy, and to deny their merit,
	  and so to deny Plaintiff's claims, in the scheme to defraud,
	  causing damage to his business, person and property, as set
	  forth in section SFI
	 for the intentional tort of

		                MALICIOUS FRAUD)

     353) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 232.

     354) Plaintiffs refer to their Memorandum on Dr. Fremed's Report
	  and Reviews [Attachment 4] as Supplementary Allegations.

     355) The Paper Review of of Plaintiff Hammel's medical records
	  dated June 30, 1999, written by Defendant Fremed, and requested
	  by Wall of Melli was presented by SFI through its attorneys
	  Melli to both Plaintiffs' attorneys, to amend Defendant's
	  answers to interrogatories as valid and professionally competent,
	  a Paper Review, while knowing that is was a sham and a
	  fabrication, and knowing the use to which it would be put,
	  in particular knowing that the Review could be submitted to
	  the Superior Court of of New Jersey, and/or an arbitration panel,
	  an adjudicating body of the State of New Jersey.  The Review
	  was submitted to the UIM arbitration panel.

     356) In so doing, Defendant SFI has committed a malicious fraud
	  in fact with knowledge and intent, foisting intentional
	  misrepresentations upon the Court, and upon Plaintiff Hammel
	  in order to slander Plaintiff Hammel's meritorious claims under
	  the policy, and to deny their merit, and so to deny Plaintiff's
	  claims, in the scheme to defraud, causing damage to his
	  business, person and property, as set forth in section SFI has
	  perpetrated on Plaintiff for a period beginning on or
	  about May 1, 1995 and continuing to the present.

     358) Plaintiff also demands judgment against the named
	  Defendant SFI for attorney fees, costs of suit and such
	  other relief as the Court deems just.


			   TWENTIETH CAUSE OF ACTION

	(Against Defendant Melli
	 for the intentional tort of

		                MALICIOUS FRAUD)

     359) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 232.

     360) Plaintiffs refer to their Memorandum on Dr. Fremed's Report
	  and Reviews [Attachment 4] as Supplementary Allegations.

     361) The Paper Review dated June 30, 1999, written by
	  Defendant Fremed, and requested by Wall of Melli was
	  by Melli to both Plaintiffs' attorneys, to amend
	  Defendant's answers to interrogatories as valid and
	  professionally competent, a Paper Review, while knowing
	  and not making reasonable investigation, that is was a
	  sham and a fabrication, and knowing the use to which it
	  would be put, in particular knowing that the Review could
	  be submitted to the Superior Court of of New Jersey,
	  and/or an arbitration panel, an adjudicating body of the
	  State of New Jersey.  The Review was submitted to the UIM
	  arbitration panel.

     362) In so doing, Defendant Melli has committed a malicious fraud
	  in fact with knowledge and intent, foisting intentional
	  misrepresentations upon the Court, and upon Plaintiff Hammel
	  in order to slander Plaintiff Hammel's meritorious claims under
	  the policy, and to deny their merit, and so to deny Plaintiff's
	  claims, in the scheme to defraud, causing damage to his
	  business, person and property, as set forth in section VIII of
	  this complaint and which is included here by reference in each
	  and every one of its paragraphs.

     363) WHEREFORE, Plaintiff demands judgment against the named
	  Defendant for actual damages to his business, property
	  and person; compensatory damages for pain, suffering
	  and extreme mental anguish resulting from the Defendant's
	  conduct; consequential damages for the foreseeable and
	  unforeseeable physical incapacitations and treatment of
	  medical sequelae; punitive and treble damages, in
	  consideration of the heedless, wanton, and oppressive,
	  malicious, and fraudulent conduct that Defendant Melli
	  has perpetrated on Plaintiff for a period beginning on
	  or about May 1, 1995 and continuing to the present.

     364) Plaintiff also demands judgment against the named
	  Defendant Melli for attorney fees, costs of suit and such
	  other relief as the Court deems just.


			   TWENTY-FIRST CAUSE OF ACTION

	(Against Defendant SFM through its employee Jim Zitney,
	 for the intentional tort of

		                 MALICIOUS FRAUD)

     365) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 207, 208, 209.

     366) On December 3, 1996, Jim Zitney, a claims specialist
	  for SFM knowingly delivered to Miller of Melli, a
	  misleading "Certification", whose purpose was to oppose
	  an Order to Show Cause why Plaintiff Hammel's cervical
	  surgery for a compressed spinal cord should not be
	  allowed, on Motion by Plaintiff's attorney
	  Mr. Paul J. Jackson.

     367) Mr. Zitney knew what the purpose of the Certification was
	  and omitted knowledge that was in his possession, and that
	  would have weakened his certification.

     368) In so doing, Defendant SFM has committed a malicious fraud
	  in fact with knowledge and intent, foisting intentional
	  misrepresentations upon the Court, and upon Plaintiff Hammel
	  in order to slander Plaintiff Hammel's meritorious claims
	  under the policy, and to deny their merit, and so to deny
	  Plaintiff's claims, in the scheme to defraud, causing damage
	  to his business, person and property, as set forth in section
	  SFM
	  has perpetrated on Plaintiff for a period beginning on
	  or about May 1, 1995 and continuing to the present.

     370) Plaintiff also demands judgment against the named
	  Defendant SFM for attorney fees, costs of suit and such
	  other relief as the Court deems just.


		      TWENTY-SECOND CAUSE OF ACTION

	(Against Defendant SFI, through its employees Matthews,
		Romei, Savastano, Murray and Wade, for the tort of

		              MALICIOUS FRAUD)

     371) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein.

     372) On or before December 3, 1996, the named employees in
	  some combination sought fraudulently through SFI's
	  attorneys Melli, in the Superior Court of New Jersey, to
	  prevent Plaintiff Hammel's medically necessary surgery
	  necessitated by the MVA of September 16, 1994.  This was
	  done by fraudulently opposing an Order to Show Cause why
	  Plaintiff Hammel's cervical surgery for a compressed
	  spinal cord should not be allowed, on Motion by Plaintiff's
	  attorney Mr. Paul J. Jackson.

     373) SFI through its agents servants and employees had clear
	  knowledge that there was damage, and that it originated
	  from the MVA.

     374) In so doing, Defendant SFI has committed a malicious fraud
	  in fact with knowledge and intent, foisting intentional
	  misrepresentations upon the Court, and upon Plaintiff Hammel
	  in order to slander Plaintiff Hammel's meritorious claims under
	  the policy, and to deny their merit, and so to deny Plaintiff's
	  claims, in the scheme to defraud, causing damage to his
	  business, person and property, as set forth in section SFI
	  has perpetrated on Plaintiff for a period beginning on
	  or about May 1, 1995 and continuing to the present.

     376) Plaintiff also demands judgment against the named
	  Defendant SFI for attorney fees, costs of suit and such
	  other relief as the Court deems just.


		        TWENTY-THIRD CAUSE OF ACTION

	(Against Defendant Melli
	 for the tort of

		              MALICIOUS FRAUD)

     377) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 207, 208, 209.

     378) On December 3, 1996, Miller of Melli, composed a
	  Certification in Opposition to Plaintiff's Application,
	  having knowledge of Plaintiff Hammel's physical damage,
	  as well as a clear line of attributions from treating
	  physicians.  Miller wrote this misleading "Certification",
	  whose purpose was to oppose an Order to Show Cause why
	  Plaintiff Hammel's cervical surgery for a compressed
	  spinal cord should not be allowed, on Motion by
	  Plaintiff's attorney Mr. Paul J. Jackson.

     379) With this knowledge, the fact omitted from the Certification
	  was what the surgery was for, and that the order for immediate
	  surgery came from Michael M. Haglund, Ph.D., M.D. a neurosurgeon
	  at Duke University Medical Center, Miller, attorney for SFI,
	  created and put this instrument of fraud into the hands of 
	  Jim Zitney, for signature and return, for the purpose of
	  defrauding the Superior Court of New Jersey in order to
	  defraud Plaintiff Hammel on behalf of SFI, and so to
	  injure his spinal cord.
	  
     380) In so doing, Defendant Melli has committed a malicious fraud
	  in fact with knowledge and intent, foisting intentional
	  misrepresentations upon the Court, and upon Plaintiff Hammel
	  in order to slander Plaintiff Hammel's meritorious claims under
	  the policy, and to deny their merit, and so to deny Plaintiff's
	  claims, in the scheme to defraud; SFI intended that the
	  medically necessary surgery not take place, having done this
	  with callous disregard for the harm that was being done to
	  Plaintiff, causing damage to his business, person and property,
	  as set forth in section Melli
	  has perpetrated on Plaintiff for a period beginning on
	  or about May 1, 1995 and continuing to the present.

     382) Plaintiff also demands judgment against the named
	  Defendant Melli for attorney fees, costs of suit and such
	  other relief as the Court deems just.


		      TWENTY-FOURTH CAUSE OF ACTION
	               
	(Against Defendants SFI and SFM
	 for the tort of

		        CONSPIRACY TO COMMIT FRAUD)

     383) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 54, 64 and 65.

     384) On or about July 12, 1993, Defendant SFM through its
	  subsidiary SFI, conspired to sell Plaintiffs a policy of
	  automobile insurance which Defendants had no intention of
	  honoring, and upon which Plaintiffs relied.

     385) On or about May 1, 1995, Defendant SFI through various of
	  its employees began a continuing conspiracy to defraud
	  plaintiffs of benefits for which they had paid under
	  that policy.

     386) In so doing, Defendant SFI has committed Conspiracy
	  to commit fraud which has been consummated and continues
	  to exist through the instruments of other unlawful acts.
	  
     387) As a result of this conspiracy, Plaintiffs have sustained
	  permanent damages to their business, property and person
	  as set forth in section SFI
	  and SFM have perpetrated on Plaintiff for a period beginning
	  on or about May 1, 1995 and continuing to the present.

     389) Plaintiffs also demand judgment against the named
	  Defendants SFI and SFM for attorney fees, costs of suit
	  and such other relief as the Court deems just.

	
	 	     TWENTY-FIFTH CAUSE OF ACTION

	(Against Defendants SFI, Savastano, Matthews, and Romei
	 for the tort of

                  ATTEMPTED CONSPIRACY TO COMMIT FRAUD)

     390) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 89.

     391) On or about January 24, 1995, Defendant SFI through its employees
	  Savastano, Romei and Matthews, attempted to enter into a
	  conspiracy with Dr. James Linder, in their fraudulent scheme
	  to terminate Plaintiff Hammel's medical benefits by obtaining
	  an IME which they could use for that purpose.

     392) Defendant, through the named employees, attempted to influence
	  Dr. Linder's report by sending him information appropriate to
	  their interest in controlling this claim, but wholly irrelevant
	  to Plaintiff Hammel's medical condition, if this were a truly
	  independent examination. For example, the amount that was paid
	  for repair to the car, as well as other presently unknown data.

     393) On or about April 28, 1995, Savastano of SFI sent Plaintiff
	  Hammel a letter ordering a second IME with Dr. Linder, which
	  Plaintiff attended on May 3, 1995.

     394) It is clear from Dr. Linder's IME reports of February 16,
	  1995 and of May 3, 1995, that Dr. Linder did not agree to
	  participate in Defendant's conspiracy, since in the former
	  he attributes Hammel's injuries to the MVA of September 16,
	  1994, and in the latter, he recommends additional treatment
	  as well as an orthopedic consult.

     395) In neither report does Dr. Linder say, or even intimate,
	  that Plaintiff Hammel needs no further treatment.

     396)  This branch of the conspiracy to terminate Plaintiff Hammel's
	   medical benefits failed to achieve its goal.

     397) In so doing, Defendant SFI has committed Attempted Conspiracy
	  to commit fraud.
	  
     398) As a result of this conspiracy, Plaintiff Hammel has
	  sustained permanent damages to his business, property and
	  person as set forth in section SFI has
	  perpetrated on Plaintiff for a period beginning on or
	  about May 1, 1995 and continuing to the present.

     400) Plaintiff also demands judgment against the named
	  Defendant SFI for attorney fees, costs of suit and such
	  other relief as the Court deems just.


		       TWENTY-SIXTH CAUSE OF ACTION
	
	(Against Defendants SFI, Savastano, Romei, and Matthews
	 for the tort of

       	                CONSPIRACY TO COMMIT FRAUD)

     401) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 89 and 97 - 99.

     402) On or about January 24, 1995, Defendant SFI through its employees
	  Savastano, Romei and Matthews, began a continuing conspiracy
	  to terminate Plaintiff Hammel's medical benefits by obtaining
	  an IME which they could use for that purpose.

     403) On or about January 25, 1995, Plaintiff Hammel received a
	  letter from SFI through Savastano, demanding an IME with
	  Dr. James F. Linder, which Plaintiff attended on February
	  15, 1995.

     404) In his report of that IME, dated February 16,1995, to
	  Savastano of SFI, Dr Linder attributes Plaintiff Hammel's
	  injuries to the MVA of September 16, 1994, and recommends
	  additional treatments.

     405) On or about April 28, 1995, Plaintiff Hammel received a
	  letter from SFI through Savastano, demanding a second IME
	  with Dr. James F. Linder, which Plaintiff attended on
	  May 3, 1995.

     406) In his report of that second IME, dated May 3,1995, to
	  Savastano of SFI, Dr Linder, again recommended additional
	  treatments for Plaintiff Hammel, as well as an orthopedic
	  evaluation for Plaintiff's impingement syndrome.

     407) Never, in either IME report, does Dr. Linder say, intimate,
	  or express an opinion that no further treatment is necessary
	  as a result of the September 16, 1994 accident.

     408) On July 27th, 1995, SFI, through Savastano, with the complicity
	  of Romei and Matthews, in continuation of the conspiracy to
	  defraud Plaintiff Hammel of his medical benefits, sent Plaintiff
	  a letter, to which Dr. Linder's report of May 3, 1995 was attached,
	  denying Plaintiff Hammel any further access to the medical
	  benefits of the PIP coverage under his policy.

     409) On July 27th, 1995, SFI, through Savastano, with the complicity
	  of Romei and Matthews, perpetuated the conspiracy to defraud
	  Plaintiff Hammel of his medical benefits, by including in her
	  letter the sentence: "In the doctor's opinion, no further
	  treatment is necessary as a result of your September 16, 1994
	  accident."

     410) Savastano took this action because it was very clear to the
	  conspirators of SFI named here that Dr. Linder was not about
	  to be suborned, and that Plaintiff Hammel's benefits had to
	  terminated quickly since the severity of injuries was becoming
	  obvious, the only recourse was a "mad dog" tactic: they lied.

     411) This conspiracy achieved its goal, and continues to achieve
	  its goal, extending into a conspiracy by the named Defendant,
	  through its named employees to a conspiracy to commit fraud,
	  achieving that goal when Savastano, in conspiracy with Romei
	  and Matthews told Plaintiff Hammel, on July 31, 1995, that the
	  denial letter "was just a formality" and that he "shouldn't
	  worry".  In its further continuation it extended into a
	  conspiracy by the named Defendant, through its named employees,
	  and included employee Murray in its conspiracy to continue to
	  defraud Plaintiff Hammel of the benefits to which he was
	  entitled, achieving that goal on and after October 18, 1995,
	  when Plaintiff's treating physicians submitted controverting
	  reports informing Defendant of Plaintiff's medical condition,
	  and Defendant SFI, through its named employees wantonly refused
	  to consider that medical information and recklessly continued
	  the denial of all medical treatment benefits to Plaintiff, in
	  complete and utter disregard for the consequences said denial
	  would have on the condition of their insured, Plaintiff Hammel.

     412) In so doing, Defendant SFI has committed Conspiracy
	  to commit fraud which has been consummated and continues to exist
	  through the instruments of other unlawful acts.
	  
     413) As a result of this conspiracy, Plaintiff Hammel has
	  sustained permanent damages to his business, property and
	  person as set forth in section SFI has
	  perpetrated on Plaintiff for a period beginning on or
	  about May 1, 1995 and continuing to the present.

     415) Plaintiff also demands judgment against the named
	  Defendant SFI for attorney fees, costs of suit and such
	  other relief as the Court deems just.


		      TWENTY-SEVENTH CAUSE OF ACTION
	
	(Against Defendants SFI, Savastano, Romei, Matthews, Murray,
         and Wagle and Psychiatric Associates
	 for the tort of

       	                CONSPIRACY TO COMMIT FRAUD)

     416) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 92, 94, 95, 111, 114, 116,
	  123 and 125.

     417) On or about April 28, 1995, Defendant SFI through its
	  employees Savastano, Romei and Matthews, began a continuing
	  conspiracy to terminate Plaintiff Bellamente's medical
	  benefits by obtaining an IME which they could use for that
	  purpose.  To achieve its conspiratorial goal, Defendant
	  SFI, through the named employees, conspired with
	  with Defendant, Psychiatric Associates, P.C., of Hackensack,
	  N.J.  Defendant, Psychiatric Associates P.C., joined the
	  conspiracy to defraud Plaintiff Bellamente of his medical
	  benefits by agreeing to provide such an IME report to the
	  SFI conspirators.

     418) Defendant, Psychiatric Associates assigned Plaintiff
	  Bellamente's IME, and the preparation of its report to
	  Defendant, Sharad Wagle, M.D. of Psychiatric Associates,
	  P.C., and related that assignment to SFI's conspirators.

     419) On or about April 29, 1995, Defendant, through employee
	  Savastano sent an IME demand for the aforementioned IME
	  to Plaintiff Hammel, in error.  On or about June 8, 1995,
	  Defendant, through employee Savastano, sent Plaintiff
	  Bellamente a demand for the IME with Dr. Wagle, to which
	  Plaintiff went, on June 28, 1995.

     420) On or about June 28, 1995, after attending the IME with
	  Dr. Wagle, Plaintiff called Defendant to express dismay
	  at his difficulty in communicating with Dr. Wagle, who
	  was from India.  Defendant's conspiracy having achieved
	  its first goal when Plaintiff presented himself for the
	  IME, they refused to discuss Plaintiff's problem of
	  communicating with the examining physician.

     421) On or about September 15, 1995, Defendant SFI, through
	  the named employees, continued its conspiracy to defraud
	  Plaintiff of medical benefits of his policy, by sending
	  to Plaintiff Bellamente a letter terminating all further
	  psychiatric benefits, based solely on the IME, performed
	  by the doctor from India, with whom Plaintiff had explained
	  to Defendant SFI, he had had difficulty communicating.

     422) Defendant, through the named employees continued this conspiracy
	  and included employee Murray in its conspiracy to defraud
	  Plaintiff of medical benefits on and after October 31, 1995,
	  when Plaintiff's treating psychotherapist, Dr. Martin Kluger,
	  sent Defendant a report, very specifically outlining errors
	  of fact and logic in Dr. Wagle's assessment of the Plaintiff,
	  and SFI through the named employees stubbornly, wantonly and
	  without regard for its insured Plaintiff maintained its
	  wrongful denial of all psychiatric benefits under the PIP
	  coverage in his policy.

     423) In so doing, Defendant SFI has committed conspiracy to
	  commit fraud which has been consummated and continues to
	  exist through the instruments of other unlawful acts.
	  
     424) As a result of this conspiracy, Plaintiff Bellamente has
	  sustained permanent damages to his business, property and
	  person as set forth in section SFI,
	  Psychiatric Associates, P.C., and Wagle have perpetrated
	  on Plaintiff for a period beginning on or about
	  May 1, 1995 and continuing to the present.

     426) Plaintiff also demands judgment against the named
	  Defendants SFI, Psychiatric Associates, P.C., and Wagle
	  for attorney fees, costs of suit and such other relief
	  as the Court deems just.


		       TWENTY-EIGHTH CAUSE OF ACTION

	(Against Defendants SFI, Savastano, Romei, Matthews, Murray,
         Rabin, and Fremed
	 for the tort of

       	                CONSPIRACY TO COMMIT FRAUD)

     427) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 91, 96, 111, 114, 116, 124,
	  and 134.

     428) On or about April 28, 1995, Defendant SFI through its
	  employees Savastano, Romei and Matthews, began a continuing
	  conspiracy to terminate Plaintiff Bellamente's medical
	  benefits by obtaining an IME which they could use for that
	  purpose.  To achieve its conspiratorial goal the named
	  Defendant, through the named employees, conspired with with
	  Defendant, Drs. Rabin & Fremed, P.C., in Englewood, N.J.
	  (Rabin).  Rabin, joined the conspiracy to defraud Plaintiff
	  Bellamente of his medical benefits by agreeing to provide
	  such an IME report to the SFI conspirators.

     429) Rabin assigned Plaintiff Bellamente's IME, and the preparation
	  of its report to Eric L. Fremed, M.D., of Rabin, and related
	  that assignment to SFI's conspirators.

     430) On or about April 29, 1995, Defendant SFI, through employee
	  Savastano sent an IME demand for the aforementioned IME to
	  Plaintiff Hammel, in error.  On or about June 8, 1995,
	  Defendant SFI, through employee Savastano, sent Plaintiff
	  Bellamente a demand for the IME with Defendant Fremed, to
	  which Plaintiff went, on July 25, 1995.

     431) On or about September 15, 1995, Defendant SFI, through the
	  named employees, continued its conspiracy to defraud
	  Plaintiff of medical benefits of his policy, by sending
	  to Plaintiff Bellamente a letter terminating all further
	  neurological benefits, based solely on the IME, performed
	  in approximately fifteen minutes, by Fremed.

     432) Defendant SFI, through the named employees continued this
	  conspiracy, and included employee Murray in its conspiracy
	  to defraud Plaintiff of medical benefits on and after
	  October 23, 1995, when Plaintiff's treating Neurosurgeon,
	  Dr Robert Rubin, sent Defendant's employee Murray a report,
	  very specifically stating that Plaintiff Bellamente had one,
	  and possibly two disc herniations, which he believed were
	  caused by the MVA, and SFI through the named employees
	  stubbornly, wantonly and without regard for its insured
	  Plaintiff maintained its wrongful denial of all neurological
	  benefits under the PIP coverage in his policy.

     433) Defendant, through the named employees continued this conspiracy,
	  and included employee Murray in its conspiracy to defraud
	  Plaintiff of medical benefits on and after November 10, 1995,
	  when Plaintiff's treating orthopedic surgeon, Dr John F. Pojedinec,
	  sent Defendant's employee Murray a letter, very specifically
	  stating that Plaintiff Bellamente's "cervical radiculopathy is
	  indeed present, is genuine and is the result of his motor vehicle
	  accident on September 16, 1994", and SFI through the named
	  employees stubbornly, wantonly and without regard for its
	  insured Plaintiff maintained its wrongful denial of all
	  neurological benefits under the PIP coverage in his policy.

     434) In so doing, Defendant SFI has committed conspiracy
	  to commit fraud which has been consummated and continues
	  to exist through the instruments of other unlawful acts.
	  
     435) As a result of this conspiracy, Plaintiff Bellamente has
	  sustained permanent damages to his business, property and
	  person as set forth in section SFI,
	  Rabin, and Fremed have perpetrated on Plaintiff for a
	  period beginning on or about May 1, 1995 and continuing
	  to the present.

     437) Plaintiff also demands judgment against the named
	  Defendants SFI, Rabin, and Fremed for attorney fees,
	  costs of suit and such other relief as the Court
	  deems just.


		       TWENTY-NINTH CAUSE OF ACTION

	(Against Defendants SFI and SFM
	 for the tort of

		        CONSPIRACY TO COMMIT FRAUD)

     438) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 161, 180 - 189, 203 and 204.

     439) On or about March 20, 1996, Defendant SFI through its employees
	  Murray, Matthews Romei and others, began a continuing conspiracy
	  with Defendant SFM, through its employees Robert Gordon, David
	  Allen Swann, Charles Allen and certain others at SFM's Asheville,
	  North Carolina office, and Jim Zitney, Joan Amzler and possibly
	  others at SFM's Franklin, North Carolina office, for the purpose
	  of having SFM deny Plaintiffs' medical benefits under the PIP
	  coverage in their policy for injuries Plaintiff's sustained in
	  the MVA of September 16, 1994.

     440) On or about March 20, 1996, Defendant SFM, through the named
	  employees, continued this conspiracy to defraud Plaintiffs'
	  of medical benefits of their policy, by receiving and accepting
	  Plaintiff's PIP file assignment, first at its Franklin, N.C.
	  office, and then referring it to its Asheville, N.C. office.

     441) On or about March 28, 1996, it appears that Defendant SFM,
	  through its employee Amzler at Franklin, attempts to implicate
	  the Plaintiff's in their conspiracy, by an entry in an activity
	  log which reads: "Insured called today to advise of new address
	  - c/o General Delivery - to the attention of Dr. Wm. c. [sic]
	  Hummel [sic], Robbinsville, N.J. [sic] 28771.  Telephone No.
	  (704) 479-1547.  He is requesting that Franklin handle PIP
	  claims."  Plaintiffs maintain that that conversation never
	  took place.

     442) On or about April 4, 1996, Defendant SFM, through its employee
	  Jim Zitney, agreed to continue the conspiracy to defraud
	  Plaintiffs in communications with Defendant SFI's employee
	  Murray.

     443) On or about May 21, 1996, Defendant SFM, through Zitney,
	  in conspiracy with SFI, through employee Murray, sent
	  Plaintiffs certified letters denying medical benefits under
	  their policy for treatment Plaintiffs received in North
	  Carolina, further defrauding Plaintiffs of their benefits
	  under their policy.

     444) On or about September 25, 1996, Defendants SFM, through
	  employee Zitney, and SFI through employee Murray, in
	  furtherance of their scheme of conspiracy to defraud
	  Plaintiff Hammel, willfully and wantonly and without regard
	  for the medical consequences on Plaintiff Hammel, denied a
	  request by Duke University Medical Center, for payment under
	  Plaintiff Hammel's PIP coverage, to perform medically necessary
	  cervical surgery which had been scheduled by Dr. Michael M.
	  Haglund, to decompress Plaintiff Hammel's cervical spinal cord.
	  Said spinal cord compression having resulted from the MVA of
	  September 16, 1994.

     445) In so doing, Defendants SFI and SFM have committed conspiracy
	  to commit fraud which has been consummated and continues to exist
	  through the instruments of other unlawful acts.
	  
     446) As a result of this conspiracy, Plaintiffs have sustained
	  permanent damages to their business, property and person as
	  set forth in section SFI and
	  SFM have perpetrated on Plaintiffs for a period beginning
	  on or about May 1, 1995 and continuing to the present.

     448) Plaintiffs also demand judgment against the named Defendants
	  SFI and SFM for attorney fees, costs of suit and such other
	  relief as the Court deems just.


		        THIRTIETH CAUSE OF ACTION

	(Against Defendants SFI, Melli, Rabin, and Fremed
	 for the tort of

		        CONSPIRACY TO COMMIT FRAUD)

     449) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 220.

     450) On or before January 5, 1999, Defendant SFI, through an unknown
	  employee, Defendant Melli, through employee Wall, Defendant Drs.
	  Rabin and Fremed, P.C., and Defendant Fremed, began a continuing
	  conspiracy to defraud Plaintiff Bellamente of his benefits under
	  his policy with SFI.

     451) On or before January 5, 1999, Defendant SFI, through an unknown
	  employee conspired with Defendant Melli, through employee Wall,
	  to defraud Plaintiff Bellamente of his benefits by SFI directing
	  Melli to procure a fraudulent medical review of Plaintiff
	  Bellamente's medical records.

     452) On or before January 5, 1999, Defendant Melli, through employee
	  Wall, conspired with Defendant Drs. Rabin and Fremed. P.C. to
	  prepare such a review as would enable the conspiracy to continue
	  to defraud Plaintiff Bellamente of the benefits under his policy
	  with SFI, and provided medical records of Plaintiff, by mail,
	  to Drs. Rabin and Fremed, P.C. in furtherance of the conspiracy
	  to to defraud Plaintiff.

     453) On or before January 5, 1999, Defendant Melli, through employee
	  Wall, conspired with Defendant Dr. Fremed to prepare such a
	  review as would enable the conspiracy to continue to defraud
	  Plaintiff Bellamente of the benefits under his policy with SFI,
	  and provided medical records of Plaintiff, by mail, to Defendant
	  Fremed in furtherance of the conspiracy to defraud Plaintiff.

     454) On or about January 5, 1999, Defendant Fremed of Drs. Rabin
	  and Fremed, P.C., produced such a report, which Defendant
	  Fremed presented as valid and professionally competent.
	  That Paper Review was based primarily on his prior fraudulent
	  IME report, and summarily dismissing the opinions and knowledge
	  of all treating healthcare givers.  While knowing that it was
	  a sham and a fabrication, and knowing the use to which it would
	  be put, in particular knowing that the Review could be submitted
	  to the Superior Court of of New Jersey, and/or an arbitration
	  panel, an adjudicating body of the State of New Jersey,
	  Defendant Fremed, nevertheless sent it to Defendant Melli,
	  specifically, to employee Wall.

     455) On information, belief and reasonable investigation,
	  Defendant Melli, through employee Wall, has submitted that
	  report to the UIM Arbitration Panel, an adjudicating body
	  in the State of New Jersey.

     456) In so doing, Defendants SFI, SFM, Melli, Drs. Rabin and
	  Fremed, P.C., and Fremed have committed Conspiracy to
	  commit fraud which has been consummated and continues
	  to exist through the instruments of other unlawful acts.
	  
     457) As a result of this conspiracy, Plaintiff Bellamente has
	  sustained permanent damages to his business, property and
	  person as set forth in section SFI,
	  Melli, Rabin and Fremed have perpetrated on Plaintiffs
	  for a period beginning on or about May 1, 1995 and
	  continuing to the present.

     459) Plaintiff also demands judgment against the named Defendants
	  SFI, Melli, Rabin, and Fremed for attorney fees, costs of
	  suit and such other relief as the Court deems just.


		       THIRTY-FIRST CAUSE OF ACTION

	(Against Defendants SFI, Melli, Rabin, and Fremed
	 for the tort of

		        CONSPIRACY TO COMMIT FRAUD)

     460) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 229.

     461) On or before June 14, 1999, Defendant SFI, through an unknown
	  employee, Defendant Melli, through employee Wall, Defendant Drs.
	  Rabin and Fremed, P.C., and Defendant Fremed, actively continued
	  their ongoing conspiracy to defraud Plaintiff Bellamente of his
	  benefits under his policy with SFI.

     462) On or before June 14, 1999, Defendant SFI, through an unknown
	  employee conspired with Defendant Melli, through employee Wall,
	  to defraud Plaintiff Bellamente of his benefits by SFI directing
	  Melli to procure a fraudulent medical review of Plaintiff
	  Bellamente's medical records.

     463) On or before June 14, 1999, Defendant Melli, through employee
	  Wall, conspired with Defendant Drs. Rabin and Fremed. P.C. to
	  prepare such a review as would enable the conspiracy to continue
	  to defraud Plaintiff Bellamente of the benefits under his policy
	  with SFI, and provided medical records of Plaintiff, by mail,
	  to Drs. Rabin and Fremed, P.C. in furtherance of the conspiracy
	  to to defraud Plaintiff.

     464) On or before June 14, 1999, Defendant Melli, through employee
	  Wall, conspired with Defendant Dr. Fremed to prepare such a
	  review as would enable the conspiracy to continue to defraud
	  Plaintiff Bellamente of the benefits under his policy with SFI,
	  and provided medical records of Plaintiff, by mail, to Defendant
	  Fremed in furtherance of the conspiracy to defraud Plaintiff.

     465) On or about June 14, 1999, Defendant Fremed of Drs. Rabin and
	  Fremed, P.C., produced such a report, in the form of another
	  Paper Review, again based primarily upon his previous fraudulent
	  IME report and containing excerpted and misleading statements,
	  as well as patently inadmissible evidence, and sent it to
	  Defendant Melli, specifically, to employee Wall.

     466) On information, belief and reasonable investigation,
	  Defendant Melli, through employee Wall, has submitted that
	  report to the UIM Arbitration Panel, an adjudicating body
	  in the State of New Jersey.

     467) In so doing, Defendants SFI and SFM have committed Conspiracy
	  to commit fraud which has been consummated and continues to exist
	  through the instruments of other unlawful acts.
	  
     468) As a result of this conspiracy, Plaintiff Bellamente has
	  sustained permanent damages to his business, property and
	  person as set forth in section SFI,
	  Melli, Rabin, and Fremed have perpetrated on Plaintiff
	  for a period beginning on or about May 1, 1995 and
	  continuing to the present.

     470) Plaintiff also demands judgment against the named Defendants
	  SFI, Melli, Rabin, and Fremed for attorney fees, costs of
	  suit and such other relief as the Court deems just.


		      THIRTY-SECOND CAUSE OF ACTION

	(Against Defendants SFI, Melli, Rabin, and Fremed
	 for the tort of

		       CONSPIRACY TO COMMIT FRAUD)

     471) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 229.

     472) On or before December 23, 1999, Defendant SFI, through an unknown
	  employee, Defendant Melli, through employee Wall, Defendant Drs.
	  Rabin and Fremed, P.C., and Defendant Fremed, actively pursued
	  their continuing conspiracy to defraud Plaintiff Bellamente of
	  his benefits under his policy with SFI.

     473) On or before December 23, 1999, Defendant SFI, through an unknown
	  employee conspired with Defendant Melli, through employee Wall,
	  to defraud Plaintiff Bellamente of his benefits by SFI directing
	  Melli to procure a fraudulent medical review of Plaintiff
	  Bellamente's medical records.

     474) On or before December 23, 1999, Defendant Melli, through employee
	  Wall, conspired with Defendant Drs. Rabin and Fremed. P.C. to
	  prepare such a review as would enable the conspiracy to continue
	  to defraud Plaintiff Bellamente of the benefits under his policy
	  with SFI, and provided medical records of Plaintiff, by mail,
	  to Drs. Rabin and Fremed, P.C. in furtherance of the conspiracy
	  to to defraud Plaintiff.

     475) On or before December 23, 1999, Defendant Melli, through employee
	  Wall, conspired with Defendant Dr. Fremed to prepare such a
	  review as would enable the conspiracy to continue to defraud
	  Plaintiff Bellamente of the benefits under his policy with SFI,
	  and provided medical records of Plaintiff, by mail, to Defendant
	  Fremed in furtherance of the conspiracy to defraud Plaintiff.

     476) On or about December 23, 1999, Defendant Fremed of Drs. Rabin
	  and Fremed, P.C., produced such a report, yet again, in the form
	  of a Paper Review containing excerpted and misleading statements,
	  and once again, ignoring any comments by healthcare givers which
	  did not suit his conspiratorial purpose, and sent it to Defendant
	  Melli, specifically, to employee Wall.

     477) On information, belief and reasonable investigation,
	  Defendant Melli, through employee Wall, has submitted that
	  report to the UIM Arbitration Panel, an adjudicating body
	  in the State of New Jersey.

     478) In so doing, Defendants SFI and SFM have committed Conspiracy
	  to commit fraud which has been consummated and continues to exist
	  through the instruments of other unlawful acts.
	  
     479) As a result of this conspiracy, Plaintiff Bellamente has
	  sustained permanent damages to his business, property and
	  person as set forth in section SFI,
	  Melli, Rabin, and Fremed have perpetrated on Plaintiff
	  for a period beginning on or about May 1, 1995 and
	  continuing to the present.

     481) Plaintiff also demands judgment against the named Defendants
	  SFI, Melli, Rabin, and Fremed for attorney fees, costs of
	  suit and such other relief as the Court deems just.


		         THIRTY-THIRD CAUSE OF ACTION

	(Against Defendants SFI, Melli, Rabin, and Fremed
	 for the tort of

		          CONSPIRACY TO COMMIT FRAUD)

     482) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 231 and 232.

     483) On or before June 30, 1999, Defendant SFI, through an unknown
	  employee, Defendant Melli, through employee Wall, Defendant Drs.
	  Rabin and Fremed, P.C., and Defendant Fremed, actively pursued
	  their continuing conspiracy to defraud Plaintiff Hammel of
	  his benefits under his policy with SFI.

     484) On or before June 30, 1999, Defendant SFI, through an unknown
	  employee conspired with Defendant Melli, through employee Wall,
	  to defraud Plaintiff Hammel of his benefits by SFI directing
	  Melli to procure a fraudulent medical review of Plaintiff
	  Hammel's medical records.

     485) On or before June 30, 1999, Defendant Melli, through employee
	  Wall, conspired with Defendant Drs. Rabin and Fremed. P.C. to
	  prepare such a review as would enable the conspiracy to continue
	  to defraud Plaintiff Hammel of the benefits under his policy
	  with SFI, and provided medical records of Plaintiff, by mail,
	  to Drs. Rabin and Fremed, P.C. in furtherance of the conspiracy
	  to to defraud Plaintiff.

     486) On or before June 30, 1999, Defendant Melli, through employee
	  Wall, conspired with Defendant Dr. Fremed to prepare such a
	  review as would enable the conspiracy to continue to defraud
	  Plaintiff Hammel of the benefits under his policy with SFI,
	  and provided medical records of Plaintiff, by mail, to Defendant
	  Fremed in furtherance of the conspiracy to defraud Plaintiff.

     487) On or about June 30, 1999, Defendant Fremed of Drs. Rabin
	  and Fremed, P.C., produced such a report in the form of a
	  Paper Review containing excerpted and misleading statements,
	  and ignoring any comments by healthcare givers which did not
	  suit his conspiratorial purpose.  The Paper Review dated June
	  30, 1999, was presented as valid and professionally competent,
	  by Fremed, while knowing that is was a sham and a fabrication,
	  and knowing the use to which it would be put, in particular
	  knowing that the Review could be submitted to the Superior
	  Court of of New Jersey, and/or an arbitration panel, an
	  adjudicating body of the State of New Jersey.

     488) Defendant Melli, through employee Wall, has submitted that
	  report to the UIM Arbitration Panel, an adjudicating body
	  in the State of New Jersey.

     489) In so doing, Defendants SFI and SFM have committed Conspiracy
	  to commit fraud which has been consummated and continues to exist
	  through the instruments of other unlawful acts.
	  
     490) As a result of this conspiracy, Plaintiff Hammel has
	  sustained permanent damages to his business, property and
	  person as set forth in section SFI,
	  Melli, Rabin, and Fremed have perpetrated on Plaintiff
	  for a period beginning on or about May 1, 1995 and
	  continuing to the present.

     492) Plaintiff also demands judgment against the named Defendants
	  SFI, Melli, Rabin, and Fremed for attorney fees, costs of
	  suit and such other relief as the Court deems just.


			 THIRTY-FOURTH CAUSE OF ACTION

	(Against Defendants SFI and SFM
	 for the tort of

	                  CONSPIRACY TO COMMIT FRAUD)

     493) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 208 and 209.

     494) On or about December 3, 1996, Defendants SFM, through
	  employee Zitney, and SFI through Defendant Melli by Miller,
	  in furtherance of their scheme of conspiracy to defraud
	  Plaintiff Hammel, attempted, by action of Zitney of SFM,
	  to thwart Plaintiff Hammel's attorney in his attempt to
	  have Hammel's surgery ordered by the Superior Court in
	  New Jersey.

     495) On or about December 3, 1996, Miller of Melli drafted an
	  artful and misleading "Certification In Opposition To
	  Plaintiff's Application", and forwarded it, by wire, to
	  Jim Zitney of SFM.

     496) On December 3, 1996, Jim Zitney, of SFM knowingly signed
	  and delivered to Miller of Melli, that same misleading
	  "Certification", whose purpose was to oppose an Order to
	  Show Cause why Plaintiff Hammel's cervical surgery for a
	  compressed spinal cord should not be allowed, on Motion
	  by Plaintiff's attorney Mr. Paul J. Jackson.

     497) Mr. Zitney knew the purpose of that artful Certification
	  and deliberately acceded in the conspiracy to omit
	  knowledge that was in his possession, but that would have
	  weakened his certification.

     498) On information, belief and reasonable investigation, Melli,
	  through Miller, submitted Zitney's signed, Miller-written
	  Certification to the Superior Court in New Jersey, further
	  conspiring to defraud Plaintiff Hammel of any medical benefits
	  under the PIP coverage of his policy.

     499) In so doing, Defendants SFI and SFM have committed Conspiracy
	  to commit fraud which has been consummated and continues to exist
	  through the instruments of other unlawful acts.
	  
     500) As a result of this conspiracy, Plaintiff Hammel has
	  sustained permanent damages to his business, property and
	  person as set forth in section SFI and
	  SFM have perpetrated on Plaintiff for a period beginning
	  on or about May 1, 1995 and continuing to the present.

     502) Plaintiff also demands judgment against the named Defendants
	  SFI and SFM for attorney fees, costs of suit and such other
	  relief as the Court deems just.


			   THIRTY-FIFTH CAUSE OF ACTION

	(Against all Defendants
	 for the violation of 18 USC 1341

		                MAIL FRAUD)

     503) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 119-123

     504) All Renewal Notices where sent by mail, so that Plaintiffs
	  paid for insurance upon which Plaintiffs relied to their
	  detriment.

     505) Each and every denial of medical benefits by mail is a
	  Predicate act of fraud in furtherance of a scheme to deny
	  meritorious claims.

     506) A scheme to defraud using the mails is defined by the
	  intentional communications by mail to Plaintiffs and among
	  all the Defendants, internally by SFM and internally by SFI,
	  that committed fraud or were in furtherance of the fraud
	  conducted by SFI and SFM.
	
     507) The acts of 384, 385 together with the scheme of 386
	  constitute mail fraud.


			   THIRTY-SIXTH CAUSE OF ACTION

	(Against all Defendants
	 for the violation of 18 USC 1343

		                WIRE FRAUD)

     508) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly, 119-123

     509) Plaintiffs reallege 118
	  Savastano's phone call was a fraud upon which Plaintiffs relied
	  to their detriment.

     510) Plaintiffs reallege 153-156
	  Matthews' phone call was a fraud upon which Plaintiffs relied
	  to their detriment.

     511) A scheme to defraud using the phone and fax is defined by
	  the intentional communications by wire to Plaintiffs and
	  among all the Defendants, and the internal electronic
	  "DESK" system that is uniform through SFM and SFI, that
	  committed fraud or were in furtherance of the fraud
	  conducted by SFI and SFM.
	
     512) The acts of 391, 392 together with the scheme of 393
	  constitute wire fraud.


		      THIRTY-SEVENTH CAUSE OF ACTION
	               
	(Against Defendants SFI for EXTORTION in violation of

		               18 USC 1951 (a))

     513) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 59.

     514) On or about September 20, 1994, Defendant SFI, through
	  Savastano, intentionally exploited Plaintiff Bellamente's
	  fear of being denied benefits under his policy if he did
	  not comply with her order to abandon his active previous
	  claim with SFM.  Defendant's act, which was a breach of
	  fiduciary duty was also the instrument of inducing this
	  fear in Plaintiff.

     515) Plaintiff Bellamente, with fear and incomplete willingness,
	  complied with SFI's edict.

     516) By its actions, Defendant SFI obtained by the inducement
	  of fear, the unused remainder of his coverage that was
	  rightfully his, arising out of an August 6, 1992 MVA,
	  committed Extortion in addition to breach of fiduciary duty.


		      THIRTY-EIGHTH CAUSE OF ACTION
	               
	(Against Defendants SFI for ROBBERY in violation of

		               18 USC 1951 (a))

     517) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 59.

     518) On or about September 20, 1994, Defendant SFI, through
	  Savastano, intentionally exploited Plaintiff Bellamente's
	  fear of being denied benefits under his policy if he did
	  not comply with her order to abandon his active previous
	  claim with SFM.  Defendant's act, which was a breach of
	  fiduciary duty was also the instrument of inducing this
	  fear in Plaintiff.

     519) Plaintiff Bellamente, with fear and incomplete willingness,
	  complied with SFI's edict. Under such a condition of fear,
	  the willingness and unwillingness, simultaneously, to
	  comply with what has been demanded is a difficult condition
	  to infer, especially when the person demanding the action is
	  in a superior position.  That a condition of willingness
	  and unwillingness should exist is not unreasonable.

     520) By its actions, Defendant SFI obtained by the inducement
	  of fear, the unused remainder of his coverage that was
	  rightfully his, arising out of an August 6, 1992 MVA,
	  and so, committed Robbery in addition to breach of
	  fiduciary duty.


		         THIRTY-NINTH CAUSE OF ACTION
	               
	(Against Defendants SFI for CONSPIRACY TO COMMIT EXTORTION
	 in violation of

		               18 USC 1951 (a))

     521) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 97 - 99, and 103.

     522) On or before July 27, 1995, SFI, through its employees
	  Savastano, Romei, Matthews, and other as yet unknown
	  persons, conspired to  commit Extortion of, and induce
	  fear in, Plaintiff Hammel, by acting unlawfully in consort,
	  to effect the plenary termination of his PIP medical benefits
	  when it had recently been discovered that his injuries were
	  more serious than they first appeared to be.  Defendant SFI is
	  responsible for the acts of its employees.  SFI has condoned
	  their action, to the present time, having been given ample
	  time and information to recant and reverse that action.  SFI
	  is also a participant, as a corporation, in this conspiracy
	  to commit extortion of, and induce fear in, Plaintiff Hammel,
	  through the chain of corporate command to its CEO Terence
	  Welsh, and beyond him, through the Parent company, SFM, to its
	  CEO Edward B. Rust, Jr., on the theory of Vicarious Liability.


		           FORTIETH CAUSE OF ACTION
	               
	(Against Defendants SFI for CONSPIRACY TO COMMIT ROBBERY
	 in violation of

		               18 USC 1951 (a))

     523) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 97 - 99, and 103.

     524) On or before July 27, 1995, SFI, through its employees
	  Savastano, Romei, Matthews, and other as yet unknown
	  persons, conspired to commit Robbery of, and induce fear
	  in, Plaintiff Hammel, by acting unlawfully in consort, to
	  effect the plenary termination of his PIP medical benefits
	  when it had recently been discovered that his injuries were
	  more serious than they first appeared to be.  Defendant
	  SFI is responsible for the acts of its employees.  SFI
	  has condoned their action, to the present time, having
	  been given ample time and information to recant and reverse
	  that action.  SFI is also a participant, as a corporation,
	  in this conspiracy to commit extortion of, and induce fear
	  in,  Plaintiff Hammel, through the chain of corporate command
	  to its CEO Terence Welsh, and beyond him, through the Parent
	  company, SFM, to its CEO Edward B. Rust, Jr., on the theory
	  of Vicarious Liability.


		           FORTY-FIRST CAUSE OF ACTION
	               
	(Against Defendants SFI, Drs. Rabin and Fremed, P.C., and
	 Fremed for CONSPIRACY TO COMMIT EXTORTION in violation of

		               18 USC 1951 (a))

     525) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 91, 96, 111 and 112.

     526) On or about April 28, 1995, Defendant SFI through its
	  employees Savastano, Romei Matthews, and other as yet
	  unknown persons, conspired with Defendants Drs. Rabin
	  and Fremed, P.C., and Fremed to commit Extortion of,
	  and induce fear in, Plaintiff Bellamente.  The named
	  conspirators sought to provide, unlawfully, a fabricated
	  and false excuse, in the form of an IME report, to
	  terminate Plaintiff Bellamente's medical (neurological)
	  benefits, when it had recently been discovered that his
	  injuries were more serious that they first appeared.  


		       FORTY-SECOND CAUSE OF ACTION
	               
	(Against Defendants SFI, Drs. Rabin and Fremed, P.C., and
	 Fremed for CONSPIRACY TO COMMIT ROBBERY in violation of

		               18 USC 1951 (a))

     527) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly 91, 96, 111 - 115.

     528) On or about April 28, 1995, Defendant SFI through its
	  employees Savastano, Romei Matthews, and other as yet
	  unknown persons, conspired with Defendants Drs. Rabin
	  and Fremed, P.C., and Fremed to commit Robbery of,
	  and induce fear in, Plaintiff Bellamente.  The named
	  conspirators sought to provide, unlawfully, a fabricated
	  and false excuse, in the form of an IME report, to
	  terminate Plaintiff Bellamente's medical (neurological)
	  benefits, when it had recently been discovered that his
	  injuries were more serious that they first appeared.  


		        FORTY-THIRD CAUSE OF ACTION
	               
	(Against Defendants SFI, Psychiatric Associates, and Wagle
	 for CONSPIRACY TO COMMIT EXTORTION in violation of

		               18 USC 1951 (a))

     529) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly: 92, 94, 95, 111, 112, 14, 116.

     530) On or about April 28, 1995, Defendant SFI through its
	  employees Savastano, Romei Matthews, and other as yet
	  unknown persons, conspired with Defendants Psychiatric
	  Associates, P.C.,and Wagle to commit extortion of, and
	  induce fear in, Plaintiff Bellamente.  The named conspirators
	  sought to provide, unlawfully, a fabricated and false excuse,
	  in the form of an IME report, to terminate Plaintiff
	  Bellamente's medical (psychiatric) benefits, when it had
	  recently been discovered that his injuries were more
	  serious than they first appeared.  


		           FORTY-FOURTH CAUSE OF ACTION
	               
	(Against Defendants SFI, Psychiatric Associates, and Wagle
	 for CONSPIRACY TO COMMIT ROBBERY in violation of

		               18 USC 1951 (a))

     531) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly: 92, 94, 95, 111, 112, 14, 116.

     532) On or about April 28, 1995, Defendant SFI through its
	  employees Savastano, Romei Matthews, and other as yet
	  unknown persons, conspired with Defendants Psychiatric
	  Associates, P.C.,and Wagle to commit Robbery of, and
	  induce fear in, Plaintiff Bellamente.  The named conspirators
	  sought to provide, unlawfully, a fabricated and false excuse,
	  in the form of an IME report, to terminate Plaintiff
	  Bellamente's medical (psychiatric) benefits, when it had
	  recently been discovered that his injuries were more
	  serious than they first appeared.  


		           FORTY-FIFTH CAUSE OF ACTION
	               
	(Against Defendant SFI,
	 for CONSPIRACY TO COMMIT EXTORTION in violation of

		               18 USC 1951 (a))

     533) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly: 91, 92, 94, 95, 96, 111,
	  and 115.

     534) On or about  September 16, 1995, Defendant SFI through its
	  employees Savastano, Wade, Romei, Matthews, and other as yet
	  unknown employees, engaged in Conspiracy to Commit Extortion
	  of, and induce fear in, Plaintiff Bellamente, by unlawfully
	  terminating his neurologic and psychiatric medical benefits
	  when it had recently been discovered that his injuries were
	  more serious than they first appeared.  SFI is responsible
	  for the acts of its employees.  SFI has condoned their action,
	  to the present time, having been given ample time and
	  information to recant and reverse that action.  SFI is also a
	  participant, as a corporation, in this Conspiracy to Commit
	  Extortion of, and induce fear in, Plaintiff Bellamente,
	  through the chain of corporate command to its CEO Terence Welsh,
	  and beyond him, through the Parent company, SFM, to its CEO
	  Edward B. Rust, Jr., on the theory of Vicarious Liability.


		           FORTY-SIXTH CAUSE OF ACTION
	               
	(Against Defendant SFI,
	 for CONSPIRACY TO COMMIT ROBBERY in violation of

		               18 USC 1951 (a))

     535) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly: 91, 92, 94, 95, 96, 111,
	  and 115.

     536) On or about  September 16, 1995, Defendant SFI through its
	  employees Savastano, Wade, Romei, Matthews, and other as yet
	  unknown employees, engaged in Conspiracy to Commit Robbery
	  of, and induce fear in, Plaintiff Bellamente, by unlawfully
	  terminating his neurologic and psychiatric medical benefits
	  when it had recently been discovered that his injuries were
	  more serious than they first appeared.  SFI is responsible
	  for the acts of its employees.  SFI has condoned their action,
	  to the present time, having been given ample time and
	  information to recant and reverse that action.  SFI is also a
	  participant, as a corporation, in this Conspiracy to Commit
	  Robbery of, and induce fear in, Plaintiff Bellamente,
	  through the chain of corporate command to its CEO Terence Welsh,
	  and beyond him, through the Parent company, SFM, to its CEO
	  Edward B. Rust, Jr., on the theory of Vicarious Liability.


		          FORTY-SEVENTH CAUSE OF ACTION
	               
	(Against Defendant SFI,
	 EXTORTION in violation of

		               18 USC 1951 (a))

     537) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly: 97 - 99, and 103

     538) On or before July 27, 1995, Defendant SFI through its
	  employees Savastano, Romei, Matthews, and other as yet
	  unknown employees, committed Extortion of, and induced
	  fear in, Plaintiff Hammel, by unlawfully effecting the
	  plenary termination of his medical benefits when it had
	  recently been discovered that his injuries were more serious
	  than they first appeared.  SFI is responsible for the acts
	  of its employees.  SFI has condoned their action, to the
	  present time, having been given ample time and information
	  to recant and reverse that action.  SFI is also a participant,
	  as a corporation, in this Extortion of, and inducement of
	  fear in, Plaintiff Hammel, through the chain of corporate
	  command to its CEO Terence Welsh, and beyond him, through
	  the Parent company, SFM, to its CEO Edward B. Rust, Jr.,
	  on the theory of Vicarious Liability.


		           FORTY-EIGHTH CAUSE OF ACTION
	               
	(Against Defendant SFI,
	 for ROBBERY in violation of

		               18 USC 1951 (a))

     539) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly: 97 - 99, and 103

     540) On or before July 27, 1995, Defendant SFI through its
	  employees Savastano, Romei, Matthews, and other as yet
	  unknown employees, committed Robbery of, and induced
	  fear in, Plaintiff Hammel, by unlawfully effecting the
	  plenary termination of his medical benefits when it had
	  recently been discovered that his injuries were more serious
	  than they first appeared.  SFI is responsible for the acts
	  of its employees.  SFI has condoned their action, to the
	  present time, having been given ample time and information
	  to recant and reverse that action.  SFI is also a participant,
	  as a corporation, in this Robbery of, and inducement of
	  fear in, Plaintiff Hammel, through the chain of corporate
	  command to its CEO Terence Welsh, and beyond him, through
	  the Parent company, SFM, to its CEO Edward B. Rust, Jr.,
	  on the theory of Vicarious Liability.


		           FORTY-NINTH CAUSE OF ACTION
	               
	(Against Defendant SFI,
	 for EXTORTION in violation of

		               18 USC 1951 (a))

     541) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly: 91, 92, 94, 95, 96, 111,
	  and 115.

     542) On or about  September 16, 1995, Defendant SFI through
	  its employees Savastano, Wade, Romei, Matthews, and other
	  as yet unknown employees, committed Extortion of, and
	  induced fear in, Plaintiff Bellamente, by unlawfully
	  terminating his neurologic and psychiatric medical benefits
	  when it had recently been discovered that his injuries were
	  more serious than they first appeared.  SFI is responsible
	  for the acts of its employees.  SFI has condoned their
	  action, to the present time, having been given ample time
	  and information to recant and reverse that action.  SFI is
	  also a participant, as a corporation, in this Extortion of,
	  and inducement fear in, Plaintiff Bellamente, through the
	  chain of corporate command to its CEO Terence Welsh, and
	  beyond him, through the Parent company, SFM, to its CEO
	  Edward B. Rust, Jr., on the theory of Vicarious Liability.


		           FIFTIETH CAUSE OF ACTION
	               
	(Against Defendant SFI,
	 ROBBERY in violation of

		               18 USC 1951 (a))

     543) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein, particularly: 91, 92, 94, 95, 96, 111,
	  and 115.

     544) On or about  September 16, 1995, Defendant SFI through
	  its employees Savastano, Wade, Romei, Matthews, and
	  other as yet unknown employees, committed Robbery of,
	  and induced fear in, Plaintiff Bellamente, by unlawfully
	  terminating his neurologic and psychiatric medical benefits
	  when it had recently been discovered that his injuries were
	  more serious than they first appeared.  SFI is responsible
	  for the acts of its employees.  SFI has condoned their
	  action, to the present time, having been given ample time
	  and information to recant and reverse that action.  SFI is
	  also a participant, as a corporation, in this Robbery of,
	  and inducement fear in, Plaintiff Bellamente, through the
	  chain of corporate command to its CEO Terence Welsh, and
	  beyond him, through the Parent company, SFM, to its CEO
	  Edward B. Rust, Jr., on the theory of Vicarious Liability.


		           FIFTY-FIRST CAUSE OF ACTION
	               
	(Against Defendant SFI,
	 for EXTORTION in violation of

		               18 USC 1951 (a))

     545) Plaintiffs refer to and incorporate by reference, each and
	  every paragraph set forth above, as though each were fully
	  set forth herein.

     546) On or about  September 16, 1995, Defendant SFI through its
	  employees Savastano, Wade, Romei, Matthews, and other as
	  yet unknown employees, by inducing of great fear,
	  committed Extortion of Plaintiffs, by unlawfully obtaining
	  money benefits due Plaintiffs, for Defendant's own use.

     547) Defendant's Extortion of Plaintiffs continued when Plaintiffs
	  were forced to litigate in order that they might recover
	  those money benefits due them which Defendants had unlawfully
	  obtained through Extortion.

     548) Defendant, by forcing Plaintiffs to litigate, in an attempt
	  to gain the money benefits to which they were entitled under
	  their policy, has continued its Extortion by delaying tactics
	  in the very litigation process itself, allowing it to keep to
	  itself for an even longer time, thereby gaining interest on
	  the extorted money, benefits which should rightfully been paid
	  to Plaintiffs, or to others on their behalf, five years ago.

     549) SFI is responsible for the acts of its employees.  SFI has
	  condoned their action, to the present time, having been given
	  ample time and information to recant and reverse that action.
	  SFI is also a participant, as a corporation, in this Extortion
	  of, and inducement fear in both Plaintiffs, through the chain
	  of corporate command to its CEO Terence Welsh, and beyond him,
	  through the Parent company, SFM, to its CEO Edward B. Rust, Jr.,
	  on the theory of Vicarious Liability.


   ____________________________________________________________________

       COUNTS OF RICO


			FIFTY-SECOND CAUSE OF ACTION

		(Against Defendant SFM for Racketeering
			 under 18 USC 1962(a))

				RICO count 1

	550) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph and all previously referenced documents set
	     forth above, as though each were fully set forth herein.

	551) For the purposes of this cause of action SFM is both the
	     "person" as defined in 18 USC 1961(3) and the "enterprise"
	     as defined in 18 USC 1961(4). It is a principal as itself
	     as defined in 18 USC Sect. 2.

	552) SFM has received income, or the proceeds, directly or
	     indirectly from its patterns of racketeering activities,
	     one pattern of which is called "claims handling".  SFM
	     uses some part of this income directly or indirectly to
	     maintain and operate itself.

	553) SFM's activities affect interstate and foreign commerce.

	554) SFM home office maintains a "divisional claims management",
	     wherein the practices of claims handling of SFM is
	     propagated to all of its wholly owned incorporated
	     subsidiaries that are insurers, so that it may be logically
	     inferred that the claims handling of SFM is equivalent to
	     that of any of these wholly owned incorporated subsidiaries;
	     SFI, is, one of these entities.

	Predicate Acts:

	555) Defendant SFM as a mutual corporation has instituted a
	     policy of defrauding, extorting and robbing its stockholders
	     who are policy holders, using multiple schemes to deny
	     policy holders all or part of the money due them from
	     meritorious claims.  Each of hundreds of thousands of
	     such action involves fraud, extortion, robbery and the
	     conspiracy to commit each of these three, in violation
	     of 18 USC 1951.

	556) Each scheme employs a system of tactics that are predicate
	     acts of the six (6) types of the previous paragraph.  In
	     addition, both mail and wire are used in effecting the
	     the myriad predicate acts, in violation of 18 USC 1341
	     and 18 USC 1343 respectively.

	557) All these schemes have a long lived continuity of approximately
	     twenty-five (25) years, and there is no evidence that they
	     will stop and so present a threat of continuation into the
	     future.

	558) All myriad criminal predicate acts of each scheme, as well
	     as the schemes themselves have same or similar purposes,
	     results, participants, victims and methods of commission,
	     or otherwise are interrelated by distinguishing
	     characteristics and are not isolated events.

	559) These predicate acts therefore constitute a pattern of
	     racketeering as defined in 18 USC 1961(1), that happen
	     to be best understood by being parsed into distinct schemes
	     of claims handling whose sole purposes are profit and
	     reckless, unjust enrichment.

	560) Plaintiffs here reference their "Memorandum On The
	     Racketeering Nature OF State Farm's Misconduct."

	561) Plaintiffs have been damaged directly by the acts of
	     Defendant SFM in the respects alleged in section VIII,
	     which is here included by reference.

	562) WHEREFORE, Plaintiffs demand judgment against Defendant
	     SFM pursuant to 18 USC 1964(c) of RICO for compensatory
	     and treble damages, together with interest thereon,
	     attorney fees, costs of suit and such other relief as
	     the Court deems just.
	
	563) Plaintiffs pray the Court, in this cause of action, that
	     the Court allow those entities named as "Other Parties
	     that are neither Plaintiffs nor Defendants" to present
	     their proofs of damages due to State Farm's patterns of
	     racketeering activities, and so seek appropriate
	     compensation for their damages pursuant to 18 USC 1964(c).

	564) Plaintiffs pray the Court also allow that these
	     entities be allowed intervenor status should
	     they seek it, and not prejudice Plaintiffs' claims.


			FIFTY-THIRD CAUSE OF ACTION

		(Against Defendant SFM for Racketeering
			 under 18 USC 1962(a))

				RICO count 2

	565) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph and all previously referenced documents set
	     forth above, as though each were fully set forth herein.

	566) SFM organized and established SFI in 1991 supposedly
	     to isolate State Farm Group's New Jersey automobile
	     business because of concerns over the pricing and
	     regulatory environment in the State.  SFI began writing
	     policies in October, 1992.  In May 1993, it started
	     renewing New Jersey policies previously written by its
	     parent.  SFI was incorporated under the laws of the
	     State of Illinois January 18, 1991.

	567) SFM has received income directly and indirectly from
	     its patterns of racketeering activities, one pattern of
	     which is called "claims handling".

	568) For the purposes of this cause of action SFM is the
	     "person" and SFI is the "enterprise". SFM is a principal
	     as defined in 18 USC Sect. 2.

	569) SFM used some part of this income directly or indirectly
	     to establish, and uses some part of this income to operate
	     SFI, and SFI affects interstate commerce, since there are
	     other insurers doing business in New Jersey who also do
	     business in other States.

	570) Although Plaintiffs seek no damages in this cause of action
	     since they cannot expect damages due others, Plaintiffs
	     pray the Court allow that those entities named as
	     "Other Parties that are neither Plaintiffs nor Defendants"
	     should be permitted to present their proofs of damage due
	     to State Farm's racketeering activities and so seek
	     appropriate compensation for their damages under
	     18 USC 1964(c).

	571) Plaintiffs pray the Court also allow that these
	     entities be allowed intervenor status should they
	     seek it, and not prejudice Plaintiffs' claims.
	

			FIFTY-FOURTH CAUSE OF ACTION

		(Against Defendant SFI for Racketeering
			 under 18 USC 1962(a))

				RICO count 3

	572) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph and all previously referenced documents set
	     forth above, as though each were fully set forth herein.

	573) SFI has received income from its patterns of racketeering
	     activities, one pattern of which is called "claims
	     handling".  For the purposes of this cause of action SFI
	     is both the "person" as defined in 18 USC 1961(3) and
	     the "enterprise" as defined in 18 USC 1961(4). It is a
	     principal as itself as defined in 18 USC Sect. 2.

	574) SFI uses some part of this income to maintain itself;
	     its interstate enterprise affects interstate commerce.

	Predicate Acts:

	575) Defendant SFI as a wholly owned incorporated subsidiary
	     of SFM has instituted a policy, dictated by its parent
	     SFM, of defrauding, extorting and robbing its policy
	     holders, using multiple schemes to deny policy holders
	     all or part of the money due them from meritorious claims.
	     Each of hundreds of thousands of such action involves
	     fraud, extortion, robbery and the conspiracy to commit
	     each of these three, in violation of 18 USC 1951.

	576) Each scheme employs a system of tactics that are predicate
	     acts of the six (6) types of the previous paragraph.  In
	     addition, both mail and wire are used in effecting the
	     the myriad predicate acts, in violation of 18 USC 1341
	     and 18 USC 1343 respectively.

	577) All these schemes have a long lived continuity of
	     approximately eight (8) years, and there is no evidence
	     that they will stop and so present a threat of continuation
	     into the future.

	578) All myriad criminal predicate acts of each scheme, as
	     well as the schemes themselves have same or similar
	     purposes, results, participants, victims and methods
	     of commission, or otherwise are interrelated by
	     distinguishing characteristics and are not isolated events.

	579) Plaintiffs allege that the one healthcare creditor,
	     Teaneck Radiology, who pursued SFI's using a collection
	     agency, received not only the payment, but interest on
	     this this payment as a result of SFI's long delays as
	     provided for by the laws of the State of New Jersey.
	     No other bills paid at that time, though some were
	     for thousands of dollars and delayed over a period of
	     years, were also paid interest according to law.  It
	     is a pattern of robbery and extortion that SFI will
	     not pay its debts, and a conspiracy with a result of
	     either robbery or extortion, from which SFI profits.
	
	580) These predicate acts therefore constitute a pattern of
	     racketeering as defined in 18 USC 1961(1), that happen
	     to be best understood by being parsed into distinct
	     schemes of claims handling whose sole purposes are
	     profit and reckless, unjust enrichment.
	
	581) Plaintiffs have been damaged directly by the acts of
	     Defendant SFM in the respects alleged in section VIII,
	     which is here included by reference.  Plaintiffs demand
	     judgement in the form of appropriate compensation for
	     their damages pursuant to 18 USC 1964(c).

	582) Plaintiffs pray the Court allow that those entities
	     named as "Other Parties that are neither Plaintiffs nor
	     Defendants" be permitted to present their proofs
	     of damage due to State Farm's racketeering activities and
	     so demand judgement in the form of appropriate compensation
	     for their damages under 18 USC 1964(c).

	583) Plaintiffs pray the Court also allow that these
	     entities be allowed intervenor status should
	     they seek it, and not prejudice Plaintiffs' claims.
	

			FIFTY-FIFTH CAUSE OF ACTION

		(Against Defendant SFI for Racketeering
			 under 18 USC 1962(a))

				RICO count 4

	584) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph and all previously referenced documents set
	     forth above, as though each were fully set forth herein.

	585) SFI has received income directly or indirectly from
	     conducting or participating in patterns of racketeering
	     activities, one pattern of which is called "claims
	     handling".  For the purposes of this cause of action
	     SFI is the "person" as defined in 18 USC 1961(3) and
	     SFI and Melli is the "enterprise", an association in
	     fact, as defined in 18 USC 1961(4). SFI is a principal
	     as defined in 18 USC Sect. 2.

	586) SFI uses some part of this income or proceeds of this
	     of this income in the establishment or operation of the
	     enterprise which is engaged in or the activities of
	     which affect interstate commerce.

	Predicate Acts:

	587) Defendant SFI as a wholly owned incorporated subsidiary
	     of SFM has instituted a policy, dictated by its parent
	     SFM, of defrauding, extorting and robbing its policy
	     holders, using multiple schemes to deny policy holders
	     all or part of the money due them from meritorious claims.
	     Each of hundreds of thousands of such action involves
	     fraud, extortion, robbery and the conspiracy to commit
	     each of these three, in violation of 18 USC 1951.

	588) Each scheme employs a system of tactics that are predicate
	     acts of the six (6) types of the previous paragraph.  In
	     addition, both mail and wire are used in effecting the
	     the myriad predicate acts, in violation of 18 USC 1341
	     and 18 USC 1343 respectively.

	589) All these schemes have a long lived continuity of
	     approximately eight (8) years, and there is no evidence
	     that they will stop and so present a threat of continuation
	     into the future.

	590) All myriad criminal predicate acts of each scheme, as
	     well as the schemes themselves have same or similar
	     purposes, results, participants, victims and methods
	     of commission, or otherwise are interrelated by
	     distinguishing characteristics and are not isolated events.

	591) SFI, through its engineered superior position in the
	     enterprise spreads its unlawful claims handling practices
	     into the litigation process with Plaintiffs, through Melli,
	     violating 18 USC 1341, 18 USC 1343, and 18 USC 1951,
	     and by inducing Melli to commit other unlaw acts.

	592) These predicate acts, therefore, constitute a pattern of
	     racketeering activity as defined in 18 USC 1961(1), that
	     happen to be best understood by being parsed into distinct
	     schemes of claims handling whose sole purposes are profit
	     and reckless, unjust enrichment.
	
	593) Plaintiffs have been damaged directly by the acts of
	     Defendant SFI in the respects alleged in section VIII,
	     which is here included by reference.

        594) WHEREFORE, pursuant to 18 USC 1964(c) Plaintiffs demand
	     judgment against the named Defendant for actual damages
	     to their businesses, property and person; compensatory damages
	     for pain, suffering and extreme mental anguish resulting
	     from the Defendant's conduct; consequential damages for
	     the foreseeable and unforeseeable physical incapacitations
	     and treatment of medical sequelae; punitive and treble
	     damages, in consideration of the heedless, wanton, and
	     oppressive, malicious, and fraudulent conduct that
	     Defendant SFI has perpetrated on Plaintiffs for a period
	     beginning on or about May 1, 1995 and continuing
	     to the present.

        595) Plaintiffs also demand judgment against the named
	     Defendant SFI for attorney fees, costs of suit and such
	     other relief as the Court deems just.

	
			FIFTY-SIXTH CAUSE OF ACTION

		(Against Defendant Melli for Racketeering
			 under 18 USC 1962(a))

				RICO count 5

	596) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph and all previously referenced documents set
	     forth above, as though each were fully set forth herein.

	597) Melli has received income directly or indirectly from
	     conducting or participating in a pattern of racketeering
	     activities, which is called "conspiracy to commit abuse of
	     process" and "abuse of process" that violate 18 USC 1951.
	     For the purposes of this cause of action Melli is the
	     "person" as defined in 18 USC 1961(3) and SFI and Melli
	     is the "enterprise", an association in fact, as defined
	     in 18 USC 1961(4).  SFI is a principal as defined in
	     18 USC Sect. 2.

	598) Melli uses some part of this income, or proceeds of this
	     income, in the establishment or operation of the
	     enterprise which is engaged in or the activities of
	     which affect interstate commerce.

	Predicate Acts:

	599) Defendant Melli is a law firm, and a professional
	     corporation which has agreed to conspire with SFI
	     to form the enterprise whose purpose is to extend
	     SFI's racketeering tactics into the litigation process
	     when denied policy holders are forced to sue SFI
	     for benefits of policies that are due the policy holders
	     of SFI upon meritorious claims.  Melli is a co-conspirator
	     and collaborator in SFI's instituted a policy, of
	     defrauding, extorting and robbing its policy holders,
	     using multiple schemes to deny policy holders all or
	     part of the money due them from meritorious claims.
	     Each of hundreds of such actions per year involves
	     fraud, extortion, robbery and the conspiracy to
	     commit each of these three, in violation of 18 USC 1951,
	     enriching both SFI and Melli, unjustly and recklessly.

	600) Each scheme employs a system of tactics that are predicate
	     acts of the six (6) types of the previous paragraph.  In
	     addition, both mail and wire are used in effecting the
	     the myriad predicate acts, in violation of 18 USC 1341
	     and 18 USC 1343 respectively.

	601) All these schemes have a continuity of length
	     unknown to Plaintiffs, but which exceeds five (5) years;
	     there is no evidence that the pattern of racketeering
	     will stop, and so it presents a threat of continuation
	     into the future.

	602) All myriad criminal predicate acts of each scheme, as
	     well as the schemes themselves have same or similar
	     purposes, results, participants, victims and methods
	     of commission, or otherwise are interrelated by
	     distinguishing characteristics and are not isolated
	     events.

	603) These predicate acts therefore constitute a pattern of
	     racketeering as defined in 18 USC 1961(1), whose sole
	     purposes are profit and reckless, unjust enrichment.
	
	604) Plaintiffs have been damaged directly by the acts of
	     Defendant Melli in the respects alleged in section VIII,
	     which is here included by reference.

        605) WHEREFORE, pursuant to 18 USC 1964(c) Plaintiffs demand
	     judgment against the named Defendant for actual damages
	     to their businesses, property and person; compensatory damages
	     for pain, suffering and extreme mental anguish resulting
	     from the Defendant's conduct; consequential damages for
	     the foreseeable and unforeseeable physical incapacitations
	     and treatment of medical sequelae; punitive and treble
	     damages, in consideration of the heedless, wanton, and
	     oppressive, malicious, and fraudulent conduct that
	     Defendant Melli has perpetrated on Plaintiffs for a
	     period beginning on or about May 1, 1995 and continuing
	     to the present.

        606) Plaintiffs also demand judgment against the named
	     Defendant Melli for attorney fees, costs of suit and such
	     other relief as the Court deems just.

	607) Plaintiffs pray the Court allow that those
	     entities named as "Other Parties that are neither
	     Plaintiffs nor Defendants" be permitted to
	     present their proofs of damage due to Melli's
	     racketeering activities and so seek appropriate
	     compensation for their damages under 18 USC 1964(c).

	608) Plaintiffs pray the Court also allow that these
	     entities be allowed intervenor status should
	     they seek it, and not prejudice Plaintiffs' claims.
	

			FIFTY-SEVENTH CAUSE OF ACTION

		(Against Defendant SFM for Racketeering
			 under 18 USC 1962(b))

				RICO count 6

	609) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph and all previously referenced documents set
	     forth above, as though each were fully set forth herein.

	610) SFM acquired and interest in or control of SFI by buying
	     281,000 outstanding common shares at a par value of $100
	     per share.  SFI has 1,500,000 authorized shares.

	611) SFM maintains an interest in SFI and a control of SFI through
	     its own patterns of racketeering activities, also a control,
	     in transference of its own patterns of racketeering activities
	     to its subsidiary corporation.

	612) SFI is engaged in, or its activities affect interstate
	     or foreign commerce.

	613) Plaintiffs have been damaged directly in their businesses
	     and property, as set forth in section VIII of this
	     complaint, by the pattern of racketeering activities and
	     predicate acts engaged in by defendant SFM, and by the
	     creation of SFI as SFM's instrument of conducting its
	     affairs in New Jersey.

        614) WHEREFORE, pursuant to 18 USC 1964(c), Plaintiffs
	     demand judgment against the named Defendant for actual
	     damages to their businesses, property and person; compensatory
	     damages for pain, suffering and extreme mental anguish
	     resulting from the Defendant's conduct; consequential
	     damages for the foreseeable and unforeseeable physical
	     incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the
	     heedless, wanton, and oppressive, malicious, and
	     fraudulent conduct that Defendant SFM has perpetrated
	     on Plaintiffs for a period beginning on or about
	     May 1, 1995 and continuing to the present.

        615) Plaintiffs also demand judgment against the named
	     Defendant SFM for attorney fees, costs of suit and such
	     other relief as the Court deems just.


			FIFTY-EIGHTH CAUSE OF ACTION

		(Against Defendants SFM, SFI and Melli for Racketeering
			 under 18 USC 1962(b))

				RICO count 7

	616) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph and all previously referenced documents set
	     forth above, as though each were fully set forth herein.

	617) For the purposes of this cause of action SFI is the
	     person and Melli is the enterprise.

	618) SFI is an incorporated, wholly owned subsidiary of SFM,
	     and under the principle of respondeat superior, SFM
	     should have vicarious liability for the actions of SFI;
	     alternatively, although SFM and SFI are indeed distinct
	     persons as defined by 18 USC 1961(3), their unusual and
	     suspect closeness in their intertwining patterns of
	     racketeering activities and other unlawful schemes demand
	     that that veil of separateness be pierced and that SFM be
	     held directly liable for the activities of SFI.

	619) Melli is engaged as attorney for SFI for a substantial
	     part of its caseload, and so profits from its association
	     with SFI.

	620) SFI has the power to cease retaining Melli as attorney
	     altogether, and therefore can control Melli.

	621) SFI maintains a control of Melli through extortionate
	     fear of suddenly losing a substantial part of its
	     cases, and through its control, SFI transfers its own
	     patterns of racketeering activities to Melli, causing Melli
	     to perform unethical, deceitful and unlawful acts in order
	     to achieve SFI's purpose, which are profit and reckless,
	     unjust enrichment.

	622) Melli is engaged in, or its activities affect, interstate
	     or foreign commerce.

	623) Plaintiffs have been damaged directly in their business
	     and property, as set forth in section VIII of this
	     complaint, by the pattern of racketeering activities and
	     predicate acts engaged in by defendants SFM, SFI and Melli.

        624) WHEREFORE, pursuant to 18 USC 1964(c), Plaintiffs demand
	     judgment against the named Defendant for actual damages
	     to their businesses, property and person; compensatory damages
	     for pain, suffering and extreme mental anguish resulting
	     from the Defendant's conduct; consequential damages for
	     the foreseeable and unforeseeable physical incapacitations
	     and treatment of medical sequelae; punitive and treble
	     damages, in consideration of the heedless, wanton, and
	     oppressive, malicious, and fraudulent conduct that
	     Defendant SFM, SFI and Melli has perpetrated on Plaintiffs
	     for a period beginning on or about May 1, 1995 and
	     continuing to the present.

        625) Plaintiffs also demand judgment against the named
	     Defendant SFM, SFI and Melli for attorney fees, costs of
	     suit and such other relief as the Court deems just.


			FIFTY-NINTH CAUSE OF ACTION

		(Against Defendant SFI for Racketeering
			 under 18 USC 1962(b))

				RICO count 8

	626) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph and all previously referenced documents set
	     forth above, as though each were fully set forth herein.

	627) For the purposes of this cause of action SFI is the
	     person and The New Jersey Department of Insurance (NJDOI)
	     is the enterprise.

	628) SFI is an insurer doing business in New Jersey and is
	     regulated by The NJDOI to which it is responsible.

	629) When a complaint is filed against SFI, or any other insurer
	     doing business in New Jersey, NJDOI investigates the complaint.

	630) NJDOI relies upon the truthfulness of the insurer in its
	     responses to investigation and interrogation by NJDOI.

	631) SFI has the power to influence the decisions of NJDOI
	     by responding in misleading, incomplete and fraudulent
	     ways, and can thus maintain control over its decisions
	     and behavior.

	632) SFI has maintained and apparently does maintain such a
	     control of NJDOI, and in so doing harms its insureds who
	     complain to NJDOI of SFI's acts which are in furtherance
	     of its pattern of racketeering activities.

	633) SFI has used this exact control over NJDOI to harm and
	     injure Plaintiffs, by intentionally providing to NJDOI,
	     misleading, obfuscatory, incomplete and therefore fraudulent
	     "information".

	634) NJDOI is engaged in, or it activities affect, interstate
	     or foreign commerce.

	635) Plaintiffs have been damaged directly in their businesses
	     and property, as set forth in section VIII of this
	     complaint, by the pattern of racketeering activities, and
	     Defendants' trickery and deception of NJDOI in attempting
	     to hide pattern of racketeering activities as well as other
	     unlawful acts committed by SFI.

        636) WHEREFORE, pursuant to 18 USC 1964(c), Plaintiffs demand
             judgment against the named Defendant for actual damages
             to their businesses, property and person; compensatory damages
             for pain, suffering and extreme mental anguish resulting
             from the Defendant's conduct; consequential damages for
             the foreseeable and unforeseeable physical incapacitations
             and treatment of medical sequelae; punitive and treble
             damages, in consideration of the heedless, wanton, and
             oppressive, malicious, and fraudulent conduct that
             Defendant SFI has perpetrated on Plaintiffs for a period
             beginning on or about May 1, 1995 and continuing
             to the present.

        637) Plaintiffs also demand judgment against the named
	     Defendant SFI for attorney fees, costs of suit and such
	     other relief as the Court deems just.


			   SIXTIETH CAUSE OF ACTION

		(Against Defendant SFM for Racketeering
			 under 18 USC 1962(b))

				RICO count 9

	638) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph and all previously referenced documents set
	     forth above, as though each were fully set forth herein.

	639) For the purposes of this cause of action SFM is the
	     person and The New Jersey Department of Insurance (NJDOI)
	     is the enterprise.

	640) SFM is an insurer doing business in New Jersey and is
	     regulated by The NJDOI to which it is responsible.

	641) When a complaint is filed against SFM, or any other insurer
	     doing business in New Jersey, NJDOI investigates the complaint.

	642) NJDOI relies upon the truthfulness of the insurer in its
	     responses to investigation and interrogation by NJDOI.

	643) SFM has the power to influence the decisions of NJDOI
	     by responding in misleading, incomplete and fraudulent
	     ways, and can thus maintain control over its decisions
	     and behavior.

	644) SFM has maintained and apparently does maintain such a
	     control of NJDOI, and in so doing harms its insureds who
	     complain to NJDOI of SFM acts which are in furtherance
	     of its pattern of racketeering activities.

	645) SFM has used this exact control over NJDOI to harm and
	     injure Plaintiffs, by intentionally providing to it,
	     misleading, obfuscatory, incomplete and fraudulent
	     "information".

	646) NJDOI is engaged in, or it activities affect, interstate
	     or foreign commerce.

	647) Plaintiffs have been damaged directly in their businesses
	     and property, as set forth in section VIII of this
	     complaint, by the pattern of racketeering activities, and
	     Defendant's trickery and deception of NJDOI in attempting to
	     hide its patterns of racketeering activities as well as other
	     unlawful acts committed by SFM.

        648) WHEREFORE, pursuant to 18 USC 1964(c), Plaintiffs demand
	     judgment against the named Defendant for actual damages
	     to their businesses, property and person; compensatory damages
	     for pain, suffering and extreme mental anguish resulting
	     from the Defendant's conduct; consequential damages for the
	     foreseeable and unforeseeable physical incapacitations and
	     treatment of medical sequelae; punitive and treble damages,
	     in consideration of the heedless, wanton, and oppressive,
	     malicious, and fraudulent conduct that Defendant SFM has
	     perpetrated on Plaintiffs for a period beginning on or
	     about May 1, 1995 and continuing to the present.

        649) Plaintiffs also demand judgment against the named
	     Defendant SFM for attorney fees, costs of suit and such
	     other relief as the Court deems just.


			SIXTY-FIRST CAUSE OF ACTION

		(Against Defendant SFI, or SFM through its Direct, or
		 Vicarious Liability through the principle of respondeat
	         superior, for Racketeering under 18 USC 1962(c))

				RICO count 10

	650) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein, specifically, 503-512, 513-547.

	651) For the purposes of this cause of action SFI is the "person"
	     as defined in 18 USC 1961(3) and SFM is the "enterprise"
	     as defined 18 USC 1961(4).

	652) SFI is associated with SFM as an incorporated wholly owned
	     subsidiary.

	653) SFM is engaged in, or its activities affect interstate or
	     foreign commerce.

	654) SFI conducts or participates, directly or indirectly in
	     in the conduct of SFM's affairs through a pattern of
	     racketeering activity.

	655) SFI has conducted SFM's affairs through a pattern of
	     racketeering when SFI, unbidden, transferred its file
	     regarding Plaintiffs' claims to SFM in North Carolina,
	     and in its instructions through its named employees, on
	     request for such instructions by named employees of
	     SFM.

	656) The Pattern of Racketeering activities is defined by the
	     nexus of interrelated alleged violations of 18 USC 1341,
	     18 USC 1342 and 18 USC 1952 as predicate acts.
	     All myriad criminal predicate acts of each scheme, as well
	     as the schemes themselves have same or similar purposes,
	     results, participants, victims and methods of commission,
	     or otherwise are interrelated by distinguishing
	     characteristics and are not isolated events.

	657) This still open pattern has a continuity starting on or
	     about May 1, 1995.
	
	658) Plaintiffs have been damaged directly in their businesses
	     and property as set forth in section VIII of this
	     complaint which is included here by reference.

        659) WHEREFORE, pursuant to 18 USC 1964(c), Plaintiffs demand
	     judgment against the named Defendant for actual damages to
	     their businesses, property and person; compensatory damages for
	     pain, suffering and extreme mental anguish resulting from
	     the Defendant's conduct; consequential damages for the
	     foreseeable and unforeseeable physical incapacitations and
	     treatment of medical sequelae; punitive and treble damages,
	     in consideration of the heedless, wanton, and oppressive,
	     malicious, and fraudulent conduct that Defendant has
	     perpetrated on Plaintiffs for a period beginning on or
	     about May 1, 1995 and continuing to the present.

        660) Plaintiffs also demand judgment against the Defendant for
	     attorney fees, costs of suit and such other relief as the
	     Court deems just.


			SIXTY-SECOND CAUSE OF ACTION

		(Against Defendant SFM for Racketeering
			 under 18 USC 1962(c))

				RICO count 11

	661) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein, specifically, 503-512, 513-547.

	662) For the purposes of this cause of action SFM is the "person"
	     as defined in 18 USC 1961(3) and SFI is the "enterprise"
	     as defined 18 USC 1961(4).

	663) SFI is associated with SFM as an incorporated wholly owned
	     subsidiary.

	664) SFI is engaged in, or its activities affect interstate or
	     foreign commerce.

	665) SFM conducts or participates, directly or indirectly in
	     in the conduct of SFI's affairs through a pattern of
	     racketeering activity.

	666) SFM has conducted SFI's affairs through a pattern of
	     racketeering activity as it has organized and capitalized
	     SFI, owning it, and controlling it as a wholly owed
	     subsidiary, merely as an alter ego: an instrument to conduct
	     and orchestrate its own affairs in the State of New Jersey
	     for the purpose of defrauding its onetime stockholders and
	     concomitant policy holders.

	667) SFM controls the claims handling procedures of SFI so
	     as to be in accordance with its own claims handling
	     procedures.

	668) The Pattern of Racketeering activities is defined by the
	     nexus of interrelated alleged violations of 18 USC 1341,
	     18 USC 1342 and 18 USC 1951 as predicate acts.
	     All myriad criminal predicate acts of each scheme, as well
	     as the schemes themselves have same or similar purposes,
	     results, participants, victims and methods of commission,
	     or otherwise are interrelated by distinguishing
	     characteristics and are not isolated events.

	669) This still open pattern has a continuity starting on or
	     about May 1, 1995.
	
	670) SFI is an incorporated, wholly owned subsidiary of SFM,
	     and under the principle of respondeat superior, SFM
	     should have vicarious liability for the actions of SFI;
	     alternatively, although SFM and SFI are indeed distinct
	     persons as defined by 18 USC 1961(3), their unusual and
	     suspect closeness in their intertwining patterns of
	     racketeering activities and other unlawful schemes demand
	     that that veil of separateness be pierced and that SFM be
	     held directly responsible for the activities of SFI.

	671) Plaintiffs have been damaged directly in their businesses
	     and property as set forth in section VIII of this
	     complaint which is included here by reference.

        672) WHEREFORE, pursuant to 18 USC 1964(c), Plaintiffs demand
	     judgment against the named Defendant for actual damages
	     to their businesses, property and person; compensatory damages
	     for pain, suffering and extreme mental anguish resulting
	     from the Defendant's conduct; consequential damages for
	     the foreseeable and unforeseeable physical incapacitations
	     and treatment of medical sequelae; punitive and treble
	     damages, in consideration of the heedless, wanton, and
	     oppressive, malicious, and fraudulent conduct that
	     Defendant SFM has perpetrated on Plaintiffs for a period
	     beginning on or about May 1, 1995 and continuing
	     to the present.

        673) Plaintiffs also demand judgment against the Defendant
	     for attorney fees, costs of suit and such other relief
	     as the Court deems just.


			SIXTY-THIRD CAUSE OF ACTION

		(Against Defendants Melli, Fremed, Rabin, Wagle,
		 and Psychiatric Associates for Racketeering

			 under 18 USC 1962(c))

				RICO count 12

	674) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein, specifically, 503-512, 513-547.

	675) For the purposes of this cause of action Melli, Fremed,
	     Rabin, Wagle and Psychiatric Associates are the "persons"
	     as defined in 18 USC 1961(3) and SFM and SFI is the
	     "enterprise" as defined 18 USC 1961(4).

	676) SFI is associated with SFM as an incorporated wholly owned
	     subsidiary.

	677) SFI and SFM as the enterprise is engaged in, or its
	     activities affect interstate or foreign commerce.

	678) Melli, Fremed, Rabin, Wagle and Psychiatric Associates
	     are all employed by the enterprise and have therefore
	     profited from the pattern of racketeering activities;
	     all conduct or participate, directly or indirectly in
	     in the conduct of the enterprise's affairs through a
	     pattern of racketeering activities.

	679) Melli, Fremed, Rabin, Wagle and Psychiatric Associates
	     direct the affairs of the enterprise by providing
	     the specific and technical tools of their special
	     knowledge in order to achieve the ends, profit and
	     reckless, unjust enrichment, of the enterprise, and
	     in so doing, profit themselves.

	680) The Pattern of Racketeering activities is defined by the
	     nexus of interrelated alleged violations of 18 USC 1341,
	     18 USC 1342 and 18 USC 1951 as predicate acts.
	     All myriad criminal predicate acts of each scheme, as well
	     as the schemes themselves have same or similar purposes,
	     results, participants, victims and methods of commission,
	     or otherwise are interrelated by distinguishing
	     characteristics and are not isolated events.

	681) This still open pattern has a continuity starting on or
	     about May 1, 1995.
	
	682) Plaintiffs have been damaged directly in their businesses
	     and property as set forth in section VIII of this
	     complaint which is included here by reference.

        683) WHEREFORE, pursuant to 18 USC 1964(c), Plaintiffs
	     demand judgment against the named Defendant for actual
	     damages to their businesses, property and person; compensatory
	     damages for pain, suffering and extreme mental anguish
	     resulting from the Defendant's conduct; consequential
	     damages for the foreseeable and unforeseeable physical
	     incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the
	     heedless, wanton, and oppressive, malicious, and fraudulent
	     conduct that Defendants has perpetrated on Plaintiffs
	     for a period beginning on or about May 1, 1995 and
	     continuing to the present.

        684) Plaintiffs also demand judgment against the named
	     Defendants for attorney fees, costs of suit and such
	     other relief as the Court deems just.


			SIXTY-FOURTH CAUSE OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee;
			Defendants: Rabin, Fremed, Wagle,
			Psychiatric Associates and Melli

			 for Racketeering under 18 USC 1962(d))

				RICO count 13

	685) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	686) For the purposes of this cause of action, SFI is the
	     "enterprise", and the other named defendants:
		Savastano, Wade, Romei, Murray, Matthews,
		Ricklemann, Davis, Ovian, Lauria, Jones,
		Muoio, Nicolosi, Clougher, Rochow, Foth,
		Rodriguez, Barrera, Fifer, Vanbreda, Roff,
		Figaro, Laub, Karasik, Lavender, Gee;
		Rabin, Fremed, Wagle and Psychiatric Associates
		and Melli
	    are the persons.

	687) Two or more of the individual Defendants combined, conspired,
	     agreed directly or indirectly, or otherwise acted in concert
	     in the affairs of the enterprise, to commit acts which
	     are unlawful and in furtherance of the violations of the above
	     counts of RICO numbered: 3, 4, 5, 8, 12,
	     though which, Plaintiffs have been damaged directly in their
	     businesses and property as set forth in section VIII of this
	     complaint which is included here by reference.
	
        688) WHEREFORE, pursuant to 18 USC 1964(c), Plaintiffs demand
	     judgment against the named Defendants for actual damages
	     to their businesses, property and person; compensatory damages
	     for pain, suffering and extreme mental anguish resulting
	     from the Defendant's conduct; consequential damages for the
	     foreseeable and unforeseeable physical incapacitations and
	     treatment of medical sequelae; punitive and treble damages,
	     in consideration of the heedless, wanton, and oppressive,
	     malicious, and fraudulent conduct that Defendants have
	     perpetrated on Plaintiffs for a period beginning on or about
	     May 1, 1995 and continuing to the present.

        689) Plaintiffs also demand judgment against the named
	     Defendants for attorney fees, costs of suit and such
	     other relief as the Court deems just.


			SIXTY-FIFTH CAUSE OF ACTION

		(Against Defendant SFM acting through its agents
			servants and employees; its named employees:
			Gordon, Swann, Kelly, King, Thompson,
			Allen, Zitney, Amzler,

			for Racketeering under 18 USC 1962(d))

				RICO count 14

	690) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	691) For the purposes of this cause of action, SFM is the
	     "enterprise", and the other named defendants:
			Gordon, Swann, Kelly, King, Thompson,
			Allen, Zitney, Amzler,
	    are the persons.

	692) Two or more of the individual Defendants combined, conspired,
	     agreed directly or indirectly, or otherwise acted in concert
	     in the affairs of the enterprise, to commit acts which
	     are unlawful and in furtherance of the violations of the above
	     counts of RICO numbered: 1, 2, 6, 9, 10,
	     though which, Plaintiffs have been damaged directly in their
	     businesses and property as set forth in section VIII of this
	     complaint which is included here by reference.

        693) WHEREFORE, pursuant to 18 USC 1964(c), Plaintiffs demand
	     judgment against the named Defendants for actual damages to
	     their businesses, property and person; compensatory damages for
	     pain, suffering and extreme mental anguish resulting from the
	     Defendant's conduct; consequential damages for the foreseeable
	     and unforeseeable physical incapacitations and treatment of
	     medical sequelae; punitive and treble damages, in consideration
	     of the heedless, wanton, and oppressive, malicious, and
	     fraudulent conduct that Defendants have perpetrated on
	     Plaintiffs for a period beginning on or about March 20,
	     1996 and with unknown continuation.

        694) Plaintiffs also demand judgment against the named
	     Defendants for attorney fees, costs of suit and such
	     other relief as the Court deems just.


			SIXTY-SIXTH CAUSE OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee;

			Defendants: Rabin, Fremed, Wagle and
			Psychiatric Associates;

			Defendant SFM acting through its agents
			servants and employees; its named employees:
			Gordon, Swann, Kelly, King, Thompson,
			Allen, Zitney, Amzler,

			for Racketeering under 18 USC 1962(d))

				RICO count 15

	695) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	696) For the purposes of this cause of action, SFM and SFI is the
	     "enterprise", and the other named defendants:
		Savastano, Wade, Romei, Murray, Matthews,
		Ricklemann, Davis, Ovian, Lauria, Jones,
		Muoio, Nicolosi, Clougher, Rochow, Foth,
		Rodriguez, Barrera, Fifer, Vanbreda, Roff,
		Figaro, Laub, Karasik, Lavender, Gee;

		Rabin, Fremed, Wagle and Psychiatric Associates

		Gordon, Swann, Kelly, King, Thompson,
		Allen, Zitney, Amzler,
	    are the persons.

	697) Two or more of the individual Defendants who are employees
	     servants or agents of SFI combined, conspired, agreed directly
	     or indirectly, or otherwise acted in concert with two or more
	     individual defendants who are agents, servants or employees
	     of SFM to participate in the affairs of the enterprise, to
	     commit acts which are unlawful and in furtherance of the
	     violations of the above counts of
	     RICO numbered: 9, 10, 12,
	     though which, Plaintiffs have been damaged directly in their
	     businesses and property as set forth in section VIII of this
	     complaint which is included here by reference.

        698) WHEREFORE, pursuant to 18 USC 1964(c), Plaintiffs demand
	     judgment against the named Defendants for actual damages to
	     their businesses, property and person; compensatory damages
	     for pain, suffering and extreme mental anguish resulting from
	     the Defendant's conduct; consequential damages for the
	     foreseeable and unforeseeable physical incapacitations and
	     treatment of medical sequelae; punitive and treble damages,
	     in consideration of the heedless, wanton, and oppressive,
	     malicious, and fraudulent conduct that Defendants have
	     perpetrated on Plaintiffs for a period beginning on or about
	     May 1, 1995 and continuing to the present.

        699) Plaintiffs also demand judgment against the named
	     Defendants for attorney fees, costs of suit and such
	     other relief as the Court deems just.



   ____________________________________________________________________

                     NORTH CAROLINA SUPPLEMENTARY ACTIONS


			SIXTY-SEVENTH CAUSE OF ACTION

	(Against Defendant SFI, or SFM as the responsible parent
	 for the intentional tort of

		                  BAD FAITH)

	700) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	701) Defendant SFI had, and still has a fiduciary duty to Plaintiff
	     Bellamente to act in Bellamente's, i.e., their insured's
	     interest over their own interest.  It did not.

	702) Defendant SFI had a a duty to investigate Bellamente's claim.
	     When it became clear through objective radiologicals that
	     Bellamente's physical damages were of a considerably more
	     serious nature than was originally apparent, Defendant SFI,
	     sought "to investigate his claims" by conspiring with two
	     physicians to produce a sham IME in order to deny Bellamente's
	     claims to medically necessary treatment.

	703) Defendant SFI conspired with Sharad Wagle, M.D. to produce
	     a sham IME in order deny Plaintiff Bellamente medically
	     necessary psychiatric treatment.

	704) Defendant SFI conspired with Eric L. Fremed, M.D. to produce
	     a sham IME in order deny Plaintiff Bellamente medically
	     necessary surgery to relieve pressure on his cervical spinal
	     cord.

	705) Despite the opinions of Dr. David J. Adams, M.D. (neurologist)
	     Robert C. Rubin, M.D (neurosurgeon) and John F. Pojedinec, M.D
	     (orthopedic surgeon), and that the appropriate surgery was
	     planned, Defendant SFI insisted on the validity of Dr. Fremed's
	     sham review to continue denial of Bellamente's surgery.

	706) Defendant SFI attempted "to investigate the claim" of Plaintiff
	     Bellamente in response by demanding an IME with a physician
	     known in medical and legal circles as a physician who's
	     business was as a medical prostitute for insurance company.

	707) Plaintiff Bellamente declined, as is his right, to be examined
	     by this physician Harry Merliss, M.D., which was sufficient
	     excuse for SFI continuing the denial, and an accusation that
	     Bellamente was being "uncooperative" with IMEs.
	
	708) Not only did Defendant SFI defraud and damage Plaintiff,
	     but it also sought to hide its fraud through deceit and
	     trickery, thus demonstrating the intention and calculation
	     of the fraud.

	709) In its continuing acts in furtherance of its fraud, with
	     the knowledge of the objective facts and preponderance of
	     independent medical opinions, Defendant SFI and SFM
	     demonstrated a reckless and wanton disregard for the damages
	     that it was inflicting on its own insured, and the consequences
	     those damages would have on the insured Plaintiff.

	710) Though Plaintiff Bellamente was reduced to poverty and
	     disability by Defendant SFI, his medically necessary
	     surgery was finally performed under Medicaid.  The delay
	     in the spinal cord decompression has left him with
	     permanent and disabling neurological injury.

	711) WHEREFORE, Plaintiff demands judgment against the named
	     Defendant(s) for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendant('s)
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendants SFI and SFM have perpetrated on Plaintiff
	     for a period beginning on or about May 1, 1995 and continuing
	     to the present.

	712) Plaintiff also demands judgment against the named
	     Defendant(s) for attorney fees, costs of suit and such
	     other relief as the Court deems just.


			SIXTY-EIGHTH CAUSE OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee;

			Defendants: Rabin, Fremed, Wagle and
			Psychiatric Associates;

			Defendant SFM acting through its agents
			servants and employees; its named employees:
			Gordon, Swann, Kelly, King, Thompson,
			Allen, Zitney, Amzler, for

	                CONSPIRACY TO COMMIT BAD FAITH)

	713) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	714) Two or more of the individual Defendants who are agents
	     servants or employees of SFI combined, conspired, agreed
	     directly or indirectly, or otherwise acted in concert with
	     two or more individual defendants who are agents, servants
	     or employees of SFM to participate in the commission of
	     Bad Faith against Plaintiff Bellamente.

	715) WHEREFORE, Plaintiff demands judgment against the named
	     Defendants for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendants SFI, SFM, Rabin, Fremed, Wagle, and
	     Psychiatric Associates, P.C., have perpetrated on Plaintiff
	     for a period beginning on or about May 1, 1995 and continuing
	     to the present.

	716) Plaintiff also demands judgment against the named
	     Defendants SFI, SFM, Rabin, Fremed, Wagle, and
	     Psychiatric Associates, for attorney fees, costs of
	     suit and such other relief as the Court deems just.


			SIXTY-NINTH CAUSE OF ACTION

	(Against Defendant SFI, or SFM as the responsible parent
	 for the intentional tort of

		                  BAD FAITH)

	717) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	718) Defendant SFI had, and still has a fiduciary duty to Plaintiff
	     Hammel to act in Hammel's, i.e., their insured's
	     interest over their own interest.  It did not.

	719) Defendant SFI had a a duty to investigate Hammel's claim.
	     When it became clear through objective radiologicals that
	     Hammel's physical damages were of a considerably more
	     serious nature than was originally apparent, Defendant SFI,
	     sought "to investigate his claims" by attempting to conspire,
	     unsuccessfully, with James F. Linder, P.T., D.C. to deny
	     Hammel's claims to medically necessary treatment.

	720) When this failed, Defendant SFI simply waited until the
	     time of Dr. Linder's suggested further treatment elapsed,
	     and then denied all medical treatment in a letter, claiming
	     that "in the doctors opinion, no further treatment was
	     necessary.", when, in fact, it recommended further
	     investigation.

	721) When confronted with this patent lie,  Savastano claimed
	     that the letter did not mean what it said, that it was a
	     formality, and Hammel shouldn't worry, which turned out to be
	     the predicate of a fraud, upon which he relied to his detriment.

	722) As a result, Hammel's diagnosed "frozen shoulder" did not
	     receive treatment prescribed by both Drs. Schmaus and
	     Savatsky for approximately two (2) years.

	723) Defendant SFI attempted "to investigate the claim" of Plaintiff
	     Hammel in response to his seeking further medical treatment
	     by demanding an IME 56 days after the denial, with a physician
	     known in medical and legal circles as a physician who's
	     business was as a medical prostitute for insurance companies.

	724) Plaintiff Hammel declined, as is his right, to be examined
	     by this physician, Harry Merliss, M.D., which was sufficient
	     excuse for SFI continuing the denial, and an accusation that
	     Hammel was being "uncooperative" with IMEs.
	
	725) As a result of SFI's fraud, the severe cervical stenosis
	     noted in Hammel's MRI series of March 10, 1995 could not
	     be brought to a neurosurgeon's attention until August 26,
	     1996.  The neurosurgeon, Dr. Michael M. Haglund of Duke
	     University Hospital and Medical Center, on the basis of
	     the March, 1995 MRIs, and his examination, suggested that
	     surgery be scheduled as quickly as possible.

	726) This surgery was denied by SFI, and SFM on or about
	     September 23, 1996.

	727) The surgery was finally had, paid for by Medicaid through SSI,
	     which recognized Hammel's disability on May 13, 1997. Surgery
	     was performed by Dr. Michael M. Haglund at Duke University
	     Hospital in Durham North Carolina.

	728) Not only did Defendant SFI defraud and damage Plaintiff,
	     but it also sought to hide its fraud through deceit and
	     trickery, thus demonstrating the intention and calculation
	     of the fraud.

	729) In its continuing acts in furtherance of its fraud, with
	     the knowledge of the objective facts and preponderance of
	     independent medical opinions, Defendants SFI and SFM
	     demonstrated a reckless and wanton disregard for the damages
	     that it was inflicting on its own insured, and the consequences
	     those damages would have on the insured Plaintiff.

	730) Though Plaintiff Hammel was reduced to poverty and
	     disability by Defendant SFI, his medically necessary
	     surgery was finally performed under Medicaid.  The delay
	     in the spinal cord decompression has left him with severe
	     permanent and disabling neurological injury, that makes
	     it impossible for him to care for himself.

	731) WHEREFORE, Plaintiff demands judgment against the named
	     Defendant(s) for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendant(s')
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendants SFI and SFM has perpetrated on Plaintiff for
	     a period beginning on or about May 1, 1995 and continuing to
	     the present.

	732) Plaintiff also demands judgment against the named
	     Defendant(s) for attorney fees, costs of suit and such
	     other relief as the Court deems just.


			SEVENTIETH CAUSE OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee;

			Defendants: Rabin, and Fremed;

			Defendant SFM acting through its agents
			servants and employees; its named employees:
			Gordon, Swann, Kelly, King, Thompson,
			Allen, Zitney, Amzler, for

		        CONSPIRACY TO COMMIT BAD FAITH)

	733) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	734) Two or more of the individual Defendants who are employees
	     servants or agents of SFI combined, conspired, agreed directly
	     or indirectly, or otherwise acted in concert with two or more
	     individual defendants who are agents, servants or employees
	     of SFM to participate in the commission of bad faith against
	     Plaintiff Hammel.

	735) WHEREFORE, Plaintiff demands judgment against the named
	     Defendants for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendants SFI and SFM have perpetrated on Plaintiff
	     for a period beginning on or about May 1, 1995 and continuing
	     to the present.

	736) Plaintiff also demands judgment against the named
	     Defendant SFI and SFM for attorney fees, costs of
	     suit and such other relief as the Court deems just.


			SEVENTY-FIRST CAUSE OF ACTION

	(Against Defendants SFI, SFM, Melli, Fremed, Rabin & Fremed,
	Wagle, and Psychiatric Associates for

		INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS)

	737) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	738) SFI sought for Plaintiff Bellamente, fraudulent IMEs from
	     Drs. Fremed and Wagle through and involving their associated
	     P.C.s, Drs. Rabin & Fremed, and Psychiatric Associates,
	     through payment for and/or arrangement of these IMEs.

	739) The purpose and effect of the IMEs was to deny Plaintiff
	     Bellamente necessary medical treatment resulting from the
	     MVA, and for which SFI is responsible.

	740) The emotional distress and severe mental anguish still
	     requiring on going psychiatric care results not from the
	     MVA itself, but from Plaintiff Bellamente being deprived
	     of his house through foreclosure, being driven into poverty,
	     and having his body injured permanently by defendants so as
	     to produce permanent physical incapacity and permanent and
	     unabating physical pain, through an outrageous, calculated
	     betrayal of trust.  Plaintiff has been diagnosed with anxiety,
	     depression and Post Traumatic Stress Disorder (PTSD).

	741) The crafty and deliberate fraud of Dr. Fremed's report and
	     and paper reviews is no accident.  They were produced in an
	     obvious and knowing conspiracy among the defendants.

	742) Defendants knew, or should have known that Plaintiff had
	     already been physically injured, and in distress enough
	     to be in psychotherapy.  The emotional distress thus
	     inflicted becomes, therefore, even more outrageous and
	     egregious.

	743) Defendants know, or should know what the consequences have
	     been, and persist in their conspiratorial fraud up to
	     the present.

	744) Defendants have continued their intentional infliction of
	     emotional distress over a period of approximately four (4)
	     years, show no signs of cessation, much less repentance.

	745) WHEREFORE, Plaintiff demands judgment against the named
	     Defendants for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that all named Defendants have perpetrated on Plaintiff for
	     a period beginning on or about May 1, 1995 and continuing
	     to the present.

	746) Plaintiff also demands judgment against the named
	     Defendants SFI, SFM, Melli, Fremed, Rabin, Wagle,
	     and Psychiatric Associates, for attorney fees, costs
	     of suit and such other relief as the Court deems just.


			SEVENTY-SECOND CAUSE OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee;

			Defendants: Rabin, Fremed, Wagle and
			Psychiatric Associates;

			Defendant SFM acting through its agents
			servants and employees; its named employees:
			Gordon, Swann, Kelly, King, Thompson,
			Allen, Zitney, Amzler, for

                        CONSPIRACY TO COMMIT
	                INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS)

	747) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	748) Two or more of the individual Defendants who are agents
	     servants or employees of SFI combined, conspired, agreed
	     directly or indirectly, or otherwise acted in concert with
	     two or more individual defendants, their agents, servants
	     or employees to participate in the commission of Intentional
	     Infliction of Emotional Distress against Plaintiff Bellamente.

	749) WHEREFORE, Plaintiff demands judgment against the named
	     Defendants for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that all named Defendants have perpetrated on Plaintiff for
	     a period beginning on or about May 1, 1995 and continuing to
	     the present.

	750) Plaintiff also demands judgment against all named
	     Defendants for attorney fees, costs of suit and such
	     other relief as the Court deems just.


			SEVENTY-THIRD CAUSE OF ACTION

	(Against Defendants SFI, SFM, Melli, Fremed, Rabin & Fremed,
	 for

		INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS)

	751) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	752) SFI denied Plaintiff Hammel's PIP benefits through fraud
	     and intentional misrepresentation, and outright lies.

	753) The purpose and effect of the IMEs was to deny Plaintiff
	     Hammel necessary medical treatment resulting from the
	     MVA, and for which SFI is responsible.

	754) The emotional distress and severe mental anguish still
	     requiring on going psychiatric care results not from the
	     MVA itself, but from Plaintiff Hammel being forced from
	     his residence through foreclosure, being driven into poverty,
	     and having his body injured permanently by defendants so as
	     to produce permanent physical incapacity and permanent and
	     unabating physical pain, through an outrageous, calculated
	     betrayal of trust. Plaintiff has been diagnosed with severe
	     anxiety, depression and Post Traumatic Stress Disorder (PTSD).

	755) The crafty and deliberate fraud of Dr. Fremed's 
	     and paper review is no accident.  It was produced in an
	     obvious and knowing conspiracy among the defendants.

	756) Defendants knew, or should have known that Plaintiff had
	     already been physically injured.  The emotional distress thus
	     inflicted becomes, therefore, even more outrageous and
	     egregious, and was sufficient to cause Plaintiff Hammel
	     to seek psychological counseling in November of 1995.

	757) Defendants know, or should know what the consequences have
	     been, and persist in their conspiratorial fraud up to
	     the present.

	758) Defendants have continued their intentional infliction of
	     emotional distress over a period of approximately four (4)
	     years, show no signs of cessation, much less repentance.

	759) WHEREFORE, Plaintiff demands judgment against the named
	     Defendants for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that all named Defendants have perpetrated on Plaintiff for
	     a period beginning on or about May 1, 1995 and continuing
	     to the present.

	760) Plaintiff also demands judgment against the named
	     Defendants SFI, SFM, Melli, Fremed, and Drs. Rabin
	     and Fremed, P.C., for attorney fees, costs of suit
	     and such other relief as the Court deems just.


			SEVENTY-FOURTH CAUSE OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee;

			Defendants: Melli, Fremed, and Rabin;

			Defendant SFM acting through its agents
			servants and employees; its named employees:
			Gordon, Swann, Kelly, King, Thompson,
			Allen, Zitney, Amzler, for


                        CONSPIRACY TO COMMIT
	                INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS)

	761) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	762) Two or more of the individual Defendants who are agents
	     servants or employees of SFI combined, conspired, agreed 
	     directly or indirectly, or otherwise acted in concert with 
	     two or more individual defendants who are agents, servants 
	     or employees of SFM, Melli, Fremed, and Rabin to participate 
	     in the commission of Intentional Infliction of Emotional
	     Distress against Plaintiff Hammel.

	763) WHEREFORE, Plaintiff demands judgment against the named
	     Defendant for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendant's
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that all named Defendants have perpetrated on Plaintiff for
	     a period beginning on or about May 1, 1995 and continuing
	     to the present.

	764) Plaintiff also demands judgment against all named
	     Defendants for attorney fees, costs of suit and such
	     other relief as the Court deems just.


			 SEVENTY-FIFTH CAUSE OF ACTION

	(Against Defendant SFI for

		       TORTIOUS BREACH OF FIDUCIARY DUTY)

	765) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	766) SFI owed Plaintiff Bellamente performance on its PIP benefits
	     of the policy for necessary medical treatment related to an MVA.

	767) An insurer's fiduciary duty to its insured exceeds that of
	     merely holding the interests of its insured's as equal to its
	     own interests.

	768) One of SFI's fiduciary duties is fairly to investigate the
	     claims of its insured.  SFI failed to do this, not simply
	     negligently, but intentionally, refusing any fair investigation.

	769) In its intentional failure to so investigate, and in its
	     termination Plaintiff's neurological and psychiatric medical
	     benefits it has committed a tortious breach of its fiduciary
	     duty.


			SEVENTY-SIXTH CAUSE OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee, for

	                CONSPIRACY TO COMMIT
	                TORTIOUS BREACH OF FIDUCIARY DUTY)

	770) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	771) Two or more of the individual Defendants who are agents
	     servants or employees of SFI combined, conspired, agreed
	     directly or indirectly, or otherwise acted in concert to
	     participate in the commission of Tortious Breach of Fiduciary
	     Duty against Plaintiff Bellamente.

	772) WHEREFORE, Plaintiff demands judgment against the named
	     Defendant for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendant's
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendant SFI has perpetrated on Plaintiff for a period
	     beginning on or about May 1, 1995 and continuing to the
	     present.

	773) Plaintiff also demands judgment against the named
	     Defendant SFI for attorney fees, costs of suit and such
	     other relief as the Court deems just.


			SEVENTY-SEVENTH CAUSE OF ACTION

	(Against Defendant SFI and SFM for

                       TORTIOUS BREACH OF FIDUCIARY DUTY)

	774) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein, particularly paragraphs 59-63, 152 and 183.

	775) One of SFI's fiduciary duties is fairly to investigate the
	     claims of its insured.  SFI failed to do this, not simply
	     negligently, but intentionally, refusing any fair investigation.

	776) On or about September 19, 1994, through Savastano, SFI breached
	     its fiduciary duty by improperly advising Plaintiff Bellamente
	     that any and all claims after the MVA of September 16, 1994,
	     (including those arising from a prior accident of August 6,
	     1992), were to be claimed under the claim number attached to
	     the later accident, despite the fact that there were continuing
	     injuries from the prior accident.  By following this improperly
	     given advice, Plaintiff Bellamente suffered the loss of coverage
	     that was due him according to the policy.

	777) Savastano (SFI) knew, or should have known that Bellamente was
	     insured under a policy issued by SFM for the 1992 MVA, and did
	     not, apparently make any distinction between the two companies.

	778) Then, as Plaintiffs have, only within approximately the past
	     month discovered, SFI conveyed SFM's medical documents relating
	     to the MVA of 1992 to SFM in North Carolina in order to confuse
	     the issue of benefits denial in collusion with SFM.

	779) In this SFI and SFM have committed a compound and tortious
	     breach of its fiduciary duty.

	780) WHEREFORE, Plaintiff demands judgment against the named
	     Defendants for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that named Defendants have perpetrated on Plaintiff for a
	     period beginning on or about May 1, 1995 and continuing to
	     the present.

	781) Plaintiff also demands judgment against the named
	     Defendants SFI and SFM for attorney fees, costs of
	     suit and such other relief as the Court deems just.


			SEVENTY-EIGHTH CAUSE OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee;

			Defendant SFM acting through its agents
			servants and employees; its named employees:
			Gordon, Swann, Kelly, King, Thompson,
			Allen, Zitney, Amzler, for

                        CONSPIRACY TO COMMIT
	                TORTIOUS BREACH OF FIDUCIARY DUTY)

	782) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	783) Two or more of the individual Defendants who are agents
	     servants or employees of SFI combined, conspired, agreed
	     directly or indirectly, or otherwise acted in concert
	     with two or more individual defendants who are agents,
	     servants or employees of SFM to participate in the
	     commission of Tortious Breach of Fiduciary Duty against
	     Plaintiff Bellamente.

	784) WHEREFORE, Plaintiff demands judgment against the named
	     Defendants for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendants SFI and SFM have perpetrated on Plaintiff
	     for a period beginning on or about May 1, 1995 and continuing
	     to the present.

	785) Plaintiff also demands judgment against the named
	     Defendants SFI and SFM for attorney fees, costs of
	     suit and such other relief as the Court deems just.


			 SEVENTY-NINTH CAUSE OF ACTION

	(Against Defendant SFI for

		       TORTIOUS BREACH OF FIDUCIARY DUTY)

	786) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	787) SFI owed Plaintiff Hammel performance on its PIP benefits
	     of the policy for necessary medical treatment related to an MVA.

	788) An insurer's fiduciary duty to its insured exceeds that of
	     merely holding the interests of its insured's as equal to its
	     own interests.

	789) One of SFI's fiduciary duties is fairly to investigate the
	     claims of its insured.  SFI failed to do this, not simply
	     negligently, but intentionally, refusing any fair investigation.

	790) In its intentional failure to so investigate and and terminate
	     medical benefits it had committed a tortious breach of its
	     fiduciary duty.

	791) WHEREFORE, Plaintiff demands judgment against the named
	     Defendant for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendant's
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendant SFI has perpetrated on Plaintiff for a period
	     beginning on or about May 1, 1995 and continuing to the
	     present.

	792) Plaintiff also demands judgment against the named
	     Defendant SFI for attorney fees, costs of suit and such
	     other relief as the Court deems just.


			EIGHTIETH CAUSE OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee, for

                        CONSPIRACY TO COMMIT
	                TORTIOUS BREACH OF FIDUCIARY DUTY)

	793) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	794) Two or more of the individual Defendants who are agents
	     servants or employees of SFI combined, conspired, agreed
	     directly or indirectly, to participate in the commission
	     of Tortious Breach of Fiduciary Duty against Plaintiff Hammel.

	795) WHEREFORE, Plaintiff demands judgment against the named
	     Defendant for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendant's
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendant SFI has perpetrated on Plaintiff for a period
	     beginning on or about May 1, 1995 and continuing to the
	     present.

	796) Plaintiff also demands judgment against the named
	     Defendant SFI for attorney fees, costs of suit and such
	     other relief as the Court deems just.


                         EIGHTY-FIRST CAUSE OF ACTION

	(Against Defendants SFI and SFM for

		         TORTIOUS BREACH OF CONTRACT)

	797) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	798) SFM owed Plaintiff Bellamente performance on the PIP
	     benefits of the policy for necessary medical treatment
	     related to an MVA of August 6, 1992 at which time a
	     policy with SFM was in force.

	799) All courts have held that in any insurance policy, when there
	     is any ambiguity of contractual language, the language of the
	     policy must be interpreted in a light most favorable to the
	     insured (The Doctrine of Reasonable Expectations).

	800) SFI and SFM have taken upon themselves to be both judge and
	     jury by maliciously interpreting what is "reasonable" under
	     the terms of a policy, in their arbitrary abrogation of
	     remaining medical benefits under the SFM policy contract.

	801) In so doing SFI and SFM have committed a tortious breach
	     of contract that is the policy.

	802) In so so doing, they have caused harm to the Plaintiff in his
	     business, finances, property, person, psyche and spirit,
	     as set forth in section VIII herein and included here by
	     reference.

	803) WHEREFORE, Plaintiff demands judgment against the named
	     Defendants for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendants SFI and SFM have perpetrated on Plaintiff
	     for a period beginning on or about May 1, 1995 and continuing
	     to the present.

	804) Plaintiff also demands judgment against the named
	     Defendants SFI and SFM for attorney fees, costs of suit
	     and such other relief as the Court deems just.


			EIGHTY-SECOND CAUSE OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee;

			Defendant SFM acting through its agents
			servants and employees; its named employees:
			Gordon, Swann, Kelly, King, Thompson,
			Allen, Zitney, Amzler, for

	                CONSPIRACY TO COMMIT
              	        TORTIOUS BREACH OF CONTRACT)

	805) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	806) Two or more of the individual Defendants who are agents
	     servants or employees of SFI combined, conspired, agreed
	     directly or indirectly, or otherwise acted in concert with
	     two or more individual defendants who are agents, servants
	     or employees of SFM to participate in the commission of
	     Tortious Breach of Contract against Plaintiff Bellamente.

	807) WHEREFORE, Plaintiff demands judgment against the named
	     Defendants for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendants SFI and SFM have perpetrated on Plaintiff
	     for a period beginning on or about May 1, 1995 and continuing
	     to the present.

	808) Plaintiff also demands judgment against the named
	     Defendants SFI and SFM for attorney fees, costs of
	     suit and such other relief as the Court deems just.


                         EIGHTY-THIRD CAUSE OF ACTION

	(Against Defendant SFI for

		         TORTIOUS BREACH OF CONTRACT)

	809) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	810) SFI owed Plaintiff Bellamente performance on its PIP benefits
	     of the policy for necessary medical treatment related to an MVA.

	811) All courts have held that in any insurance policy, when there
	     is any ambiguity of contractual language, the language of the
	     policy must be interpreted in a light most favorable to the
	     insured (The Doctrine of Reasonable Expectations).

	812) SFI has taken upon itself to be both judge and jury by
	     maliciously interpreting what is "reasonable" and what is
	     "medically necessary" treatment, in its summary denial of this
	     Plaintiff's psychiatric and neurological medical benefits.

	813) In so doing SFI has committed a tortious breach of contract
	     that is the policy.

	814) In so so doing, it has caused harm to the Plaintiff in his
	     business, finances, property, person, psyche and spirit,
	     as set forth in section VIII herein and included here by
	     reference.

	815) WHEREFORE, Plaintiff demands judgment against the named
	     Defendant for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendant's
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendant SFI has perpetrated on Plaintiff for a period
	     beginning on or about May 1, 1995 and continuing to the
	     present.

	816) Plaintiff also demands judgment against the named
	     Defendant SFI for attorney fees, costs of suit and
	     such other relief as the Court deems just.


			EIGHTY-FOURTH CAUSE OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee, for

                        CONSPIRACY TO COMMIT
	                TORTIOUS BREACH OF CONTRACT)

	817) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	818) Two or more of the individual Defendants who are agents
	     servants or employees of SFI combined, conspired, agreed
	     directly or indirectly, or otherwise acted in concert to
	     participate in the commission of Tortious Breach of Contract
	     against Plaintiff Bellamente.

	819) WHEREFORE, Plaintiff demands judgment against the named
	     Defendant for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendant's
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendant SFI has perpetrated on Plaintiff for a period
	     beginning on or about May 1, 1995 and continuing to the
	     present.

	820) Plaintiff also demands judgment against the named
	     Defendant SFI for attorney fees, costs of suit and such
	     other relief as the Court deems just.


                         EIGHTY-FIFTH CAUSE OF ACTION

	(Against Defendant SFI for

		         TORTIOUS BREACH OF CONTRACT)

	821) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	822) SFI owed Plaintiff Hammel performance on its PIP benefits
	     of the policy for necessary medical treatment related to an MVA.

	823) All courts have held that in any insurance policy, when there
	     is any ambiguity of contractual language, the language of the
	     policy must be interpreted in a light most favorable to the
	     insured (The Doctrine of Reasonable Expectations).

	824) SFI has taken upon itself to be both judge and jury by
	     maliciously interpreting what is "reasonable" and what is
	     "medically necessary" treatment, in its plenary denial of
	     Plaintiff Hammel's medical benefits.

	825) In so doing SFI has committed a tortious breach of contract
	     that is the policy.

	826) In so so doing, it has caused harm to the Plaintiff in his
	     business, finances, property, person, psyche and spirit,
	     as set forth in section VIII herein and included here by
	     reference.

	827) WHEREFORE, Plaintiff demands judgment against the named
	     Defendant for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendant's
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendant SFI has perpetrated on Plaintiff for a period
	     beginning on or about May 1, 1995 and continuing to the
	     present.

	828) Plaintiff also demands judgment against the named
	     Defendant SFI for attorney fees, costs of suit and
	     such other relief as the Court deems just.


			EIGHTY-SIXTH CAUSE OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee, for

                        CONSPIRACY TO COMMIT
	                TORTIOUS BREACH OF CONTRACT)

	829) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	830) Two or more of the individual Defendants who are agents
	     servants or employees of SFI combined, conspired, agreed
	     directly or indirectly, or otherwise acted in concert to
	     participate in the commission of Tortious Breach of Contract
	     against Plaintiff Hammel.

	831) WHEREFORE, Plaintiff demands judgment against the named
	     Defendant for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendant's
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendant SFI has perpetrated on Plaintiff for a period
	     beginning on or about May 1, 1995 and continuing to the
	     present.

	832) Plaintiff also demands judgment against the named
	     Defendant SFI for attorney fees, costs of suit and
	     such other relief as the Court deems just.


                        EIGHTY-SEVENTH CAUSE OF ACTION

	(Against Defendant SFI and SFM for

		         TORTIOUS BREACH OF CONTRACT)

	833) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	834) SFI and SFM owed Plaintiff Hammel performance on the PIP
	     benefits of the policy for necessary medical treatment
	     related to an MVA.

	835) All courts have held that in any insurance policy, when there
	     is any ambiguity of contractual language, the language of the
	     policy must be interpreted in a light most favorable to the
	     insured (The Doctrine of Reasonable Expectations).

	836) SFI and SFM have taken upon themselves to be both judge and
	     jury by maliciously interpreting what is "reasonable" and
	     what is "medically necessary" treatment, by their summary
	     denial of medically necessary surgery for Plaintiff Hammel.

	837) In so doing SFI and SFM have committed a tortious breach of
	     contract that is the policy.

	838) In so so doing, they have caused harm to the Plaintiff in his
	     business, finances, property, person, psyche and spirit,
	     as set forth in section VIII herein and included here by
	     reference.

	839) WHEREFORE, Plaintiff demands judgment against the named
	     Defendants for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendants SFI and SFM have perpetrated on Plaintiff
	     for a period beginning on or about May 1, 1995 and continuing
	     to the present.

	840) Plaintiff also demands judgment against the named
	     Defendants SFI and SFM for attorney fees, costs of
	     suit and such other relief as the Court deems just.


			EIGHTY-EIGHTH CAUSE OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee;

			Defendant SFM acting through its agents
			servants and employees; its named employees:
			Gordon, Swann, Kelly, King, Thompson,
			Allen, Zitney, Amzler, for

                        CONSPIRACY TO COMMIT
	                TORTIOUS BREACH OF CONTRACT)

	841) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	842) Two or more of the individual Defendants who are agents
	     servants or employees of SFI combined, conspired, agreed
	     directly or indirectly, or otherwise acted in concert with
	     two or more individual defendants who are agents, servants
	     or employees of SFM to participate in the commission of
	     Tortious Breach of Contract against Plaintiff Hammel.

	843) WHEREFORE, Plaintiff demands judgment against the named
	     Defendants for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendant SFI and SFM have perpetrated on Plaintiff
	     for a period beginning on or about May 1, 1995 and continuing
	     to the present.

	844) Plaintiff also demands judgment against the named
	     Defendants SFI and SFM for attorney fees, costs of
	     suit and such other relief as the Court deems just.


                         EIGHTY-NINTH CAUSE OF ACTION

	(Against Defendant SFI for

		         TORTIOUS BREACH OF CONTRACT)

	845) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	846) SFI owes Plaintiff Hammel performance on its settlement
	     contract with Plaintiff, which Plaintiff signed in good faith.

	847) SFI has not paid Plaintiff Hammel specified "out of pocket"
	     expenses, to which, under the terms of the settlement contract,
	     he is entitled.

	848) In so doing SFI is still committing a tortious breach of
	     contract that is the settlement.

	849) In so so doing, it has caused harm to the Plaintiff in his
	     business, finances, property, person, psyche and spirit,
	     as set forth in section VIII herein and included here by
	     reference.

	850) WHEREFORE, Plaintiff demands judgment against the named
	     Defendant for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendant's
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendant SFI has perpetrated on Plaintiff for a period
	     beginning on or about May 1, 1995 and continuing to the
	     present.

	851) Plaintiff also demands judgment against the named
	     Defendant SFI for attorney fees, costs of suit and
	     such other relief as the Court deems just.


			NINETIETH CAUSE OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee, for

                        CONSPIRACY TO COMMIT
	                TORTIOUS BREACH OF CONTRACT)

	852) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	853) Two or more of the individual Defendants who are agents
	     servants or employees of SFI combined, conspired, agreed
	     directly or indirectly, or otherwise acted in concert to
	     participate in the commission of Tortious Breach of Contract
	     against Plaintiff Hammel.

	854) WHEREFORE, Plaintiff demands judgment against the named
	     Defendant for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendant's
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendant SFI has perpetrated on Plaintiff for a period
	     beginning on or about May 1, 1995 and continuing to the
	     present.

	855) Plaintiff also demands judgment against the named
	     Defendant SFI for attorney fees, costs of suit and such
	     other relief as the Court deems just.


			  NINETY-FIRST CAUSE OF ACTION

	(Against Defendant SFM

		      TORTIOUS INTERFERENCE WITH CONTRACT)

	856) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	857) Plaintiffs had a valid contract as insurance policy with SFI,
	     conferring on Plaintiffs contractual rights against SFI.

	858) Defendant SFM knew of the existence of the contract.

	859) Defendant SFM has intentionally induced SFI not to
	     perform the contract.

	860) Defendant SFM acted without justification.

	861) Defendant SFM's conduct has caused actual pecuniary harm
	     to the Plaintiffs.

	862) In so doing, it has caused harm to the Plaintiffs in their
	     business, finances, property, person, psyche and spirit,
	     as summarized in section VIII herein.

	863) WHEREFORE, Plaintiffs demand judgment against the named
	     Defendant for actual damages to their business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendant's
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendant SFM has perpetrated on Plaintiffs for a period
	     beginning on or about May 1, 1995 and continuing to the
	     present.

	864) Plaintiffs also demand judgment against the named
	     Defendant SFM for attorney fees, costs of suit and
	     such other relief as the Court deems just.


			NINETY-SECOND CAUSE OF ACTION

		(Against Defendant SFM acting through its agents
			servants and employees; its named employees:
			Gordon, Swann, Kelly, King, Thompson,
			Allen, Zitney, Amzler, for

	                CONSPIRACY TO COMMIT
	                TORTIOUS INTERFERENCE WITH CONTRACT)

	865) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	866) Two or more of the individual Defendants who are agents
	     servants or employees of SFM combined, conspired, agreed
	     directly or indirectly, or otherwise acted in concert to
	     participate in the commission of Tortious Interference
	     With Contract against Plaintiffs.

	867) WHEREFORE, Plaintiffs demand judgment against the named
	     Defendant for actual damages to their business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendant's
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendant SFI has perpetrated on Plaintiff for a period
	     beginning on or about May 1, 1995 and continuing to the
	     present.

	868) Plaintiffs also demand judgment against the named
	     Defendant SFM for attorney fees, costs of suit and
	     such other relief as the Court deems just.


			 NINETY-THIRD CAUSE OF ACTION

	(Against Defendant SFI

		      TORTIOUS INTERFERENCE WITH CONTRACT)

	869) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	870) Plaintiffs had a valid contract as insurance policy with SFM,
	     conferring on Plaintiffs contractual rights against SFM.

	871) Defendant SFI knew of the existence of the contract.

	872) Defendant SFI has intentionally induced SFM not to
	     perform the contract.

	873) Defendant SFI acted without justification.

	874) Defendant SFI's conduct has caused actual pecuniary harm
	     to the Plaintiffs.

	875) In so so doing, it has caused harm to the Plaintiffs in
	     their business, finances, property, person, psyche and
	     spirit, as summarized in section VIII herein.

	876) WHEREFORE, Plaintiffs demand judgment against the named
	     Defendant for actual damages to their business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendant's
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendant SFI has perpetrated on Plaintiffs for a period
	     beginning on or about May 1, 1995 and continuing to the
	     present.

	877) Plaintiffs also demand judgment against the named
	     Defendant SFI for attorney fees, costs of suit and
	     such other relief as the Court deems just.


			NINETY-FOURTH CAUSE OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee, for

	                CONSPIRACY TO COMMIT
	                TORTIOUS INTERFERENCE WITH CONTRACT)

	878) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	879) Two or more of the individual Defendants who are agents
	     servants or employees of SFI combined, conspired, agreed
	     directly or indirectly, or otherwise acted in concert to
	     participate in the commission of Tortious Interference With
	     Contract against Plaintiffs.

	880) WHEREFORE, Plaintiffs demand judgment against the named
	     Defendant for actual damages to their business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendant's
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendant SFI has perpetrated on Plaintiff for a period
	     beginning on or about May 1, 1995 and continuing to the
	     present.

	881) Plaintiff also demands judgment against the named
	     Defendant SFI for attorney fees, costs of suit and
	     such other relief as the Court deems just.


	        	NINETY-FIFTH CAUSE OF ACTION

	(Against Defendants SFI, SFM, Melli for

		         TORTIOUS ABUSE OF PROCESS)

	882) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	883) SFI and Melli extended the tactics that SFI used in the
	     handling of claims for Plaintiff Bellamente, avoiding
	     depositions, procuring and submitting fabricated medical
	     reports to an adjudicating arbitration panel that is to
	     decide an award in a UIM dispute in New Jersey.

	884) The ulterior motive was exactly the ulterior motives of SFI
	     and SFM, when SFM took it upon itself, unbidden, to handle
	     the claims of both Plaintiffs, and that motive is to not pay
	     any claims, so that they might be unjustly enriched.

	885) In so doing the named Defendants have committed tortious
	     abuse of process.

	886) In so doing, it has caused harm to the Plaintiffs in their
	     business, finances, property, person, psyche and spirit,
	     as set forth in section VIII herein and included here by
	     reference.
	
	887) WHEREFORE, Plaintiff demands judgment against the named
	     Defendants for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendants SFI, SFM, and Melli, have perpetrated on
	     Plaintiff for a period beginning on or about May 1, 1995
	     and continuing to the present.

	888) Plaintiff also demands judgment against the named
	     Defendants SFI, SFM, and Melli, for attorney fees,
	     costs of suit and such other relief as the Court deems just.


			NINETY-SIXTH CAUSE OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee;

			Defendant: Melli;

			Defendant SFM acting through its agents
			servants and employees; its named employees:
			Gordon, Swann, Kelly, King, Thompson,
			Allen, Zitney, Amzler, for

                        CONSPIRACY TO COMMIT
	                TORTIOUS ABUSE OF PROCESS)

	889) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	890) Two or more of the individual Defendants who are agents
	     servants or employees of SFI combined, conspired, agreed
	     directly or indirectly, or otherwise acted in concert with
	     two or more individual defendants who are agents, servants
	     or employees of SFM and/or Melli, to participate in the
	     commission of Tortious Abuse of Process against Plaintiff
	     Bellamente.

	891) WHEREFORE, Plaintiff demands judgment against the named
	     Defendants for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendants SFI, SFM, and, Melli have perpetrated on
	     Plaintiff for a period beginning on or about May 1, 1995
	     and continuing to the present.

	892) Plaintiff also demands judgment against the named
	     Defendants SFI, SFM, and Melli, for attorney fees, costs
	     of suit and such other relief as the Court deems just.


			NINETY-SEVENTH CAUSE OF ACTION

	(Against Defendants SFI, SFM, Melli for

		         TORTIOUS ABUSE OF PROCESS)

	893) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	894) SFI and Melli extended the tactics that SFI used in the
	     handling of claims for Plaintiff Hammel, avoiding
	     depositions, submitting a deliberately defective
	     certification to the Superior Court of New Jersey, and
	     procuring and submitting fabricated medical reports to an
	     adjudicating arbitration panel that is to decide an award
	     in a UIM dispute in New Jersey.  The deliberately defective
	     certification was manufactured by Miller of Melli, for the
	     signature of Jim Zitney, at the Franklin office of SFM.

	895) The ulterior motive was exactly the ulterior motives of SFI
	     and SFM, when SFM took it upon itself, unbidden, to handle
	     the claims of both Plaintiffs, and that motive is to not pay
	     any claims, so that they might be unjustly enriched.

	896) In so doing the named Defendants have committed tortious abuse
	     of process.

	897) In so so doing, it has caused harm to the Plaintiff in his
	     business, finances, property, person, psyche and spirit,
	     as set forth in section VIII herein and included here by
	     reference.
	
	898) WHEREFORE, Plaintiff demands judgment against the named
	     Defendants for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendants have perpetrated on Plaintiff for a period
	     beginning on or about May 1, 1995 and continuing to the
	     present.

	899) Plaintiff also demands judgment against the named
	     Defendants SFI, SFM, and Melli, for attorney fees,
	     costs of suit and such other relief as the Court
	     deems just.


			NINETY-EIGHTH CAUSE OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee;

			Defendant: Melli;

			Defendant SFM acting through its agents
			servants and employees; its named employees:
			Gordon, Swann, Kelly, King, Thompson,
			Allen, Zitney, Amzler, for

                        CONSPIRACY TO COMMIT
	                TORTIOUS ABUSE OF PROCESS)

	900) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein.

	901) Two or more of the individual Defendants who are agents
	     servants or employees of SFI combined, conspired, agreed
	     directly or indirectly, or otherwise acted in concert with
	     two or more individual defendants who are agents, servants
	     or employees of SFM and/or Melli, to participate in the
	     commission of Tortious Abuse of Process against
	     Plaintiff Hammel.

	902) WHEREFORE, Plaintiff demands judgment against the named
	     Defendants for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendants SFI, SFM, and, Melli have perpetrated on
	     Plaintiff for a period beginning on or about May 1, 1995
	     and continuing to the present.

	903) Plaintiff also demands judgment against the named
	     Defendants SFI, SFM, and Melli, for attorney fees, costs
	     of suit and such other relief as the Court deems just.


	NINETY-NINTH through ONE HUNDRED and TWENTY-FIRST CAUSES OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee;
			Defendants: Rabin, Fremed, Wagle and
			Psychiatric Associates;

			Defendant SFM acting through its agents
			servants and employees; its named employees:
			Gordon, Swann, Kelly, King, Thompson,
			Allen, Zitney, Amzler, for

		               COMMON LAW FRAUD)

	904) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein, particularly 250-382.

	905) Plaintiffs reallege causes of action ONE through TWENTY-THREE
	     against the defendants particularized within those counts
	     of fraud.

	906) These acts of fraud have caused direct harm to Plaintiffs
	     each in his business, finances, property, person, psyche
	     and spirit, as set forth in section VIII herein and included
	     here by reference.
	
	907) WHEREFORE, Plaintiffs demand judgment against the named
	     Defendants for actual damages to his business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendants SFI and SFM have perpetrated on Plaintiffs
	     for a period beginning on or about May 1, 1995 and continuing
	     to the present.

	908) Plaintiffs also demand judgment against the named
	     Defendants SFI and SFM for attorney fees, costs of
	     suit and such other relief as the Court deems just.


	ONE HUNDRED and TWENTY-SECOND through ONE HUNDRED and THIRTY-SECOND
				CAUSES OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee;
			Defendants: Rabin, Fremed, Wagle and
			Psychiatric Associates;

			Defendant SFM acting through its agents
			servants and employees; its named employees:
			Gordon, Swann, Kelly, King, Thompson,
			Allen, Zitney, Amzler, for

	          CONSPIRACY TO COMMIT COMMON LAW FRAUD)

	909) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein, particularly 383-502.

	910) Plaintiffs reallege causes of action TWENTY-FOUR through
	     THIRTY-FOUR against the defendants particularized within
	     those counts of conspiracy to commit fraud.

	911) These conspiracies of fraud have caused direct harm to
	     Plaintiffs each in his business, finances, property, person,
	     psyche and spirit, as set forth in section VIII herein and
	     included here by reference.
	
	912) WHEREFORE, Plaintiffs demand judgment against the named
	     Defendants for actual damages to their business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendants have perpetrated on Plaintiffs for a period
	     beginning on or about May 1, 1995 and continuing to the
	     present.

	913) Plaintiff also demands judgment against the named
	     Defendants for attorney fees, costs of suit and such
	     other relief as the Court deems just.


	ONE HUNDRED and THIRTY-THIRD through ONE HUNDRED and THIRTY-SIXTH
				CAUSES OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee;
			Defendants: Rabin, Fremed, Wagle and
			Psychiatric Associates;

			Defendant SFM acting through its agents
			servants and employees; its named employees:
			Gordon, Swann, Kelly, King, Thompson,
			Allen, Zitney, Amzler, for

	           COMMON LAW EXTORTION)

	914) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein, particularly 513-547

	915) Plaintiffs reallege causes of action 27, 47, 49, 51,
	     against the defendants particularized within those counts
	     of extortion.

	916) These acts of extortion have caused direct harm to Plaintiffs
	     each in his business, finances, property, person, psyche
	     and spirit, as set forth in section VIII herein and included
	     here by reference.
	
	917) WHEREFORE, Plaintiffs demand judgment against the named
	     Defendants for actual damages to their business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendants have perpetrated on Plaintiffs for a period
	     beginning on or about May 1, 1995 and continuing to the
	     present.

	918) Plaintiffs also demand judgment against the named
	     Defendants for attorney fees, costs of suit and such
	     other relief as the Court deems just.


	ONE HUNDRED and THIRTY-SEVENTH through ONE HUNDRED and FORTIETH
				CAUSES OF ACTION

		(Against Defendant SFI acting through its agents
			servants and employees; its named employees:
			Savastano, Wade, Romei, Murray, Matthews,
			Ricklemann, Davis, Ovian, Lauria, Jones,
			Muoio, Nicolosi, Clougher, Rochow, Foth,
			Rodriguez, Barrera, Fifer, Vanbreda, Roff,
			Figaro, Laub, Karasik, Lavender, Gee;

			Defendants: Rabin, Fremed, Wagle and
			Psychiatric Associates;

			Defendant SFM acting through its agents
			servants and employees; its named employees:
			Gordon, Swann, Kelly, King, Thompson,
			Allen, Zitney, Amzler, for

	          CONSPIRACY TO COMMIT COMMON LAW EXTORTION)

	919) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein, particularly 513-547.

	920) Plaintiffs reallege causes of action 39, 41, 43, 45,
	     against the defendants particularized within
	     those counts of conspiracy to commit extortion.

	921) These conspiracies of extortion have caused direct harm to
	     Plaintiffs each in his business, finances, property, person,
	     psyche and spirit, as set forth in section VIII herein and
	     included here by reference.
	
	922) WHEREFORE, Plaintiffs demand judgment against the named
	     Defendants for actual damages to their business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that named Defendants have perpetrated on Plaintiffs for a
	     period beginning on or about May 1, 1995 and continuing to
	     the present.

	923) Plaintiffs also demand judgment against the named
	     Defendants for attorney fees, costs of suit and such
	     other relief as the Court deems just.


		    ONE HUNDRED and FORTY-FIRST CAUSE OF ACTION

	(Against all Defendants for

		      TORTIOUS INTERFERENCE WITH DUE PROCESS)

	924) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein, particularly 813-826.

	925) All defendants have consistently and systematically
	     sought to delay and deny both Plaintiffs' right to due
	     process in the resolution of their initial PIP and
	     UIM claims under the policy issued by SFI, with no
	     justification other than unjust enrichment.

	926) In so doing the named Defendants have committed tortious
	     interference with due process.

	927) In so so doing, it has caused harm to the Plaintiffs in their
	     business, finances, property, person, psyche and spirit
	     as set forth in section VIII herein and included here by
	     reference.

	928) WHEREFORE, Plaintiffs demand judgment against the named
	     Defendants for actual damages to their business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendants have perpetrated on Plaintiffs for a period
	     beginning on or about May 1, 1995 and continuing to the
	     present.

	929) Plaintiffs also demand judgment against the named
	     Defendants for attorney fees, costs of suit and such
	     other relief as the Court deems just.


		  ONE HUNDRED and FORTY-SECOND CAUSE OF ACTION

	(Against all Defendants for

			 CONSPIRACY TO COMMIT
		         TORTIOUS INTERFERENCE WITH DUE PROCESS)

	930) Plaintiffs refer to and incorporate by reference, each and
	     every paragraph set forth above, as though each were fully
	     set forth herein, particularly 813-826, 848-852.

	931) Two or more of the individual Defendants combined, conspired,
	     agreed directly or indirectly, or otherwise acted in concert
	     to commit acts which are unlawful and in furtherance of
	     a tortious interference with Plaintiffs' right to due
	     process.

	932) In so so doing, it has caused harm to the Plaintiffs in their
	     business, finances, property, person, psyche and spirit
	     as set forth in section VIII herein and included here by
	     reference.

	933) WHEREFORE, Plaintiffs demand judgment against the named
	     Defendants for actual damages to their business, property
	     and person; compensatory damages for pain, suffering
	     and extreme mental anguish resulting from the Defendants'
	     conduct; consequential damages for the seeable and unforeseeable
	     physical incapacitations and treatment of medical sequelae;
	     punitive and treble damages, in consideration of the heedless,
	     wanton, and oppressive, malicious, and fraudulent conduct
	     that Defendants have perpetrated on Plaintiffs for a period
	     beginning on or about May 1, 1995 and continuing to the
	     present.

	934) Plaintiffs also demand judgment against the named
	     Defendants for attorney fees, costs of suit and such
	     other relief as the Court deems just.



   ____________________________________________________________________

        VIII. SUMMARY OF DAMAGES


	935) Included here by reference is Plaintiffs' Memorandum
	     on Damages and Causality.

	936) Damages to Business and Property of Plaintiffs as a
	     direct and proximate result of Defendants' acts,
	     schemes, patterns of racketeering activities,
	     and other unlawful acts:

		   1. Plaintiff Hammel

		      a) Loss of the business known as Lex*Data
		        (William C. Hammel. d/b/a Lex*data)

		      b) Loss of the business known as Ultra Videos
		        (William C. Hammel, d/b/a Ultra Videos)

		      c) Loss of valuable business property
 
		      d) Loss of valuable personal property
 
		      e) Loss of money interest in property at 219 Teaneck
		         Road, Ridgefield Park, N.J.

		      f) Loss of money interest in a classic Mercedes Benz.

		      g) Loss of valuable business reputation and contacts.   

		      h) Loss of all future income, expected and anticipated.


		   2. Plaintiff Bellamente

		      a) Loss of equity in property at 219 Teaneck Road,
		         Ridgefield Park, N.J.

		      b) Loss of valuable business reputation and contacts.   

		      c) Loss of income from The Conservatorship of
		         Edna M. Clough.

		      d) Loss of all future income, expected and anticipated.


	937) Permanent physical losses of Plaintiffs as a direct
	     result of Defendants' continuing unlawful actions in
	     furtherance of denial and delays in medical treatment:

             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
                         region.
                      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

              Continued physical therapy:
              Both Plaintiffs have had temporary, but no enduring
	      results from several courses of physical therapy.

              Continued psychotherapy:
              Both Plaintiffs remain in psychotherapy as a result of
              Defendants' fraudulent denials and delays of medically
	      necessary treatments and the multitudinous sequelae of
	      those actions that grow like the roots of a tree.


        IX. RELIEF SOUGHT


        938) 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 cited 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 may
             not be 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.

        939) Relief in the form of $60,000,000.00 for direct and actual
	     damages, proximately caused damages to life, limb, well being
	     and finances of Plaintiffs stemming from Defendants' actions,
             as will be outlined and apportioned, future damages that will
	     have such lifelong irreparable effect as severe pain, severe
             disabilities and severe mental an physical impairments and
	     incapacitation, that permanently prohibit Plaintiffs from being
	     self supporting, productive individuals, as well as punitive
	     damages.

	     BUSINESS DAMAGES

	     PROPERTY DAMAGES

	     PERSONAL DAMAGES

		actual damages
		consequential damages
		future damages

	     PUNITIVE DAMAGES

        940) 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;

        941) Any and all interest and late payment charges 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.

        942) 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".

        943) All Plaintiffs' Costs in this litigation, and as well,
	     pursuant to FRCP 9(g) just compensation for the destructive
	     and onerous work and effort that has been extorted from
	     Plaintiffs, under physical and emotional duress, and 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.
	     Such special damages can only be assessed at a time of
	     judgment or settlement.

        944) Restitution of all Premiums paid to Defendants for
             any services that Defendants have purported to provide, over
	     any time that SFM and SFI has ever been paid for such purported
             insurance services, under the Collateral Source Rule.

        945) 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.


        X. DEMAND FOR JUDGMENT

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


        XI. PLAINTIFFS' AVERMENT REGARDING RULE 11, FRCP


        947) 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.

        948) 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.

	949) 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
	     FRCP.

	Respecfully 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 15, 2000               DATE: February 15, 2000 




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The URL for this document is:
http://graham.main.nc.us/~bhammel/RICO/complaint2.html
Created: February 5, 2000
Last Updated: May 28, 2000