The Progress of this case will be followed from a


in chronological order with links to appropriate documents.

Cf. Affidavit of Donald Carringer, M.D.


             WILLIAM C. HAMMEL,                    |
             ALAN J. BELLAMENTE,                   |
             et al.,                               |  MEMORANDUM/ANALYSIS OF
                                                   |  A MEDICAL PAPER REVIEW
                                                   |      BY DEFENDANT
                   vs.                             |   ERIC L. FREMED, M.D.
                                                   |  ON PLAINTIFF HAMMEL's
             INSURANCE CO.,                        |
             STATE FARM INDEMNITY COMPANY,         |
             et al.                                |     No. 2:99:CV-44-T
                  Defendants                       |


	BY ERIC L. FREMED, M.D., DATED 06/30/99

	Authored by Plaintiff William C. Hammel, Ph.D.


	It is the purpose of this memorandum to compare and
	contrast the text of Dr. Fremed's review with the texts
	of the medical reports themselves.  These reports consist
	of two IME reports by Dr. James Linder ordered by State
	Farm Indemnity, truly independent radiological reports,
	reports of healthcare givers as well as deposition

	This analysis will demonstrate that Dr. Fremed's conclusion:
	"based on the medical records reviewed thus far however,
         that Dr. Hammel suffered no permanent neurologic injuries as
	 a result of the accident in question and that his cervical
	 surgery was not necessitated by the accident in question."
	 is gotten to by:

	1) Failing to divulge the totality of documents with which
	   he was provided, by either SFI or Melli;

	2) Failing, in particular, to divulge that he had read
	   the complaint written by me on behalf of Plaintiff
	   Bellamente to the New Jersey DOI, [Exhibit B] in which I
	   criticized his IME report for many of the tactics of deceit,
	   trickery and fraud that are exposed in his review of my
	   medical records found in the review analysed here;

	3) Ignoring any reports or notes that were in contradiction
           to his conclusion;

	4) Systematically omitting from his purported review all
	   statements of attribution by treating healthcare givers;

	5) Systematically making constructions to his point through
	   careful selections and omissions that alter the meaning
	   of the reports;

	6) Neglecting the continuous medical care that has been
	   required from the the MVA date of 09/16/94;

	7) failing to note any details of the MVA;

	8) failing to remark on, reason that, or take into account:

		a) That Plaintiff Bellamente was previously injured
		   in an MVA of 08/06/92, for which SFM is
		   responsible in PIP coverage;

		b) That Plaintiff Hammel had never been injured in a
		   automobile accident, and was actively athletic
		   prior to the MVA of 09/16/94, as well as completely
		   asymptomatic of any supposed "pre-existing" condition.
		   Cf. e.g. appendix 6 herein,  Dr. Schmaus's remark
		   of his report of 06/26/95, "Examination reveals a
		   male who has a strong upper body presence ..."
		   Plaintiff Hammel was, however, in a maximal spinal
		   twist at the time of impact.

        9) Using of manipulative innuendo in order to impugn the
	   integrity and competence of treating physicians;

       10) The modern "snake oil" salesman technique, which is to
	   dazzle with being 90%-95% professionally correct in
	   what is said, and then slip in, at a crucial moment,
	   the turn from truth and logic to mendacity, which sells
	   the snake oil.

       11) An improper and unprofessional ad hominem attack on
	   Plaintiff Hammel.

	Thus, it will be important to note what Dr. Fremed does not write
	as well as what he does write in this sham review.

	The purpose of a medical review is arrive at a balanced,
	independent and unbiased assessment of all available records
	that arrives at a reasonable scientific truth.  Dr. Fremed
	fails utterly in these standards, as the following analysis
	will show.


	Dr. Fremed's purported review, to the contrary, is a fabrication
	designed explicitly to come to his preordained conclusion, "that
	Dr. Hammel suffered no permanent neurologic injuries as a result
	of the accident in question and that his cervical surgery was not
	necessitated by the accident in question."  Were this conclusion
	accepted, it would deny Plaintiff Hammel all remedies for the
	many and maliciously caused damages of great variety that have been
	inflicted on him by the the defendants in this case.  Dr. Fremed
	knows very well the intent and purpose of his review, and
	should know what the total probable damages are; either that,
	or he is genuinely incompetent to practice medicine which is
	highly unlikely.  Dr. Fremed's review is an act of coldly
	calculated abetting of robbery.

	It should be noted that, Wall of Melli, requested this review,
	as shown by the salutation and opening paragraph; and further
	noted that it was presented as valid by Wall to a UIM arbitration
	panel, which is to say, an adjudicating body equivalent to a
	Court of Law in the State of New Jersey.  A suggestion of perjury
	on the part of both Melli and Fremed is presented to the Court.
	1.  We note that this "review" has been requested by
	    Michelle Wall of SFI's attorneys Melli, Guerin & Melli.

	2.  In paragraph 2, page 1, Dr. Fremed states:

		"Records provided for review included:"

	    which is to say that there were possibly other documents
	    in his possession which he chooses not to divulge.

	3.  Paragraph 2 continues with a list of "some" of the
	    documents under review, citing:

	    1. A copy of Mr. Hammel's deposition transcript of 2/25/98.
	    2. Mr. Hammel's answers to interrogatories. (unavailable)
	    3. Records from Dr. Peter Boulukos.
	    4. Records from Dr. James Linder.
	    5. Reports from Teaneck Radiology Center.
	    6. Records from Dr. Peter Schmaus.
	    7. Records from Dr. Albert Stabile. (unavailable)
	    8. Records from Dr. Martin Kluger.
	    9. Records from Dr. Paul Sender.
	   10. Records from Dr. Gary Savatsky.
	   11. Records from Andrews Family Chiropractic Center.
	   12. Records from Smoky Mountain Center for Mental Health
	       Developmental Disability and Substance Abuse Services.
	   13. Records from Duke University Medical Center.
               (Records of Michael M. Haglund, PhD, MD & radiological)

	   These very records are attached to this analysis as appendices
	   grouped under these numbers, exactly for the point of comparison
	   with what Dr. Fremed chooses and does not choose to include in his
	   "review".  Note that exactly which records have been reviewed
	   are not precisely defined, even as stated.

	   [NB: the HTML version does not reproductions of these documents]

	4. In the last paragraph of page 1, the word "apparently" is
	   used, calling into question what is an obvious fact of
	   reality.  Must one not slow down to turn into a driveway from
	   a major thoroughfare?  Any layman knows the answer, and yet
	   this innuendo is inserted.

	   Dr. Fremed cannot be using the word in its first meaning,
	   since he was not there.

	5. On Page 2 paragraph 1,  Dr. Fremed describes from Dr. Boulukos'
	   notes, the exact conditions that any neurologist would have
	   understood as possibly involving, at least, radiculopathy
	   in the neighborhood of C5-C6, and makes no comment at all.

	   Dr. Fremed does not mention the statements of causal
	   attribution of the then current symptoms to the MVA by
	   Dr. Boulukos, although they are there.  See any of the
	   "Attending Physician Reports" sent periodically to
	   Savastano.  Each report answers the question as to whether
	   the condition is SOLELY a result of this accident
	   with a YES; answers the question as to whether patient ever
	   had same or similar condition with a NO.

	   Dr. Boulukos' initial diagnosis is rather clearer: "847.0
	   Acute Traumatic Hyperflexion/extension of Cervical Spine;
	   723.3 Cervicobrachial Syndrome; 738.4 Spondylolithesis L-2,3"

	   Dr. Fremed fails, completely, even to mention this primal
	   and immediate diagnosis by one who was aware of Plaintiff
	   Hammel's prior physical condition.

	   I stated in my deposition before SFI's attorney Donna
	   Miller that I was a weight trainer and that once every
	   three or four weeks I had seen Dr. Boulukos aperiodically
	   for simple prophylactic adjustments.  This is fairly
	   common among weight trainers and body builders, and this
	   is how I came to know Dr. Boulukos and why I sought his
	   help first.

	   My deposition was in Dr. Fremed's possession and was
	   reported to have been reviewed.  Cf. #1 in the non-specific
	   list of documents said to have been reviewed.

	   Dr. Fremed fails to note that Dr. Boulukos was in a very
	   special position to notice the difference between a damaged
	   body that he examined the morning of 09/17/94 and the prior
	   healthy body he had adjusted many times before. In doing
	   so, Dr. Fremed fails to give to these attributions by
	   Dr. Boulukos their proper medical significance.  These
	   attributions record the suddenness of the onset of symptoms
	   immediately following the MVA, and further record a
	   prior asymptomatic state.

	6. On Page 2 paragraph 2, what Dr. Fremed describes is correct
	   in quoting from Dr. Linder's report, and from my deposition.
	   However this is what is missing:

	   In both of Dr. Linder's reports of 02/16/95 and 05/03/95,
	   on the last page of each, one can find attribution, in his
	   professional opinion, of the then current symptoms to MVA.
	   Dr. Linder, in his 02/16/95 report expressed concern about
	   a possible Right shoulder impingement syndrome, which is
	   in concurrence with Dr. Boulukos's original diagnosis.
	   Although it is accurately quoted from Dr. Linder's report
	   of 02/16/95, I have no idea where "slightly" rotated
	   came from.

	   It should be noted that Dr. Linder was SFI's own IME.

	7. The physically necessary uncoiling from the twisted position
	   in order to try to stablize my body by quickly bracing myself
	   against the dashboard with my hand, which is documented ad
	   nauseum in other medical reports and records, seems either
	   to have eluded me or Dr. Linder and so, is not in his first
	   report.  As reviewer, Dr. Fremed should have been aware of
	   this.  As noted many times in this analysis, Dr. Fremed
	   evades any possible connection between the symptoms
	   objectively observed by many treating physicians with the
	   radiological evidence cited as a possible "prior injury"
	   in the penultimate sentence on page 2. paragraph 3 of his

	8. Dr. Fremed denies having the cervical MRIs of 03/10/95,
	   which could easily have been gotten before writing such
	   a momentous review, and we question his denial in the
	   context of the review's entirety.

	9. Without Cervical MRIs, Dr. Fremed quotes the radiological
	   report of the allegedly missing cervical MRIs of 03/10/95,
	   the analysis of which would fall into his area of expertise.
	   At the time he wrote this review, a quintuple laminectomy
	   C3-C7 of my C-spine had already been performed, so delayed
	   that it has left me in severe pain of various kinds and
	   degeneration of all the major muscles of my body.  Of course,
	   Dr. Fremed could be exculpated from any mistaken diagnosis
	   since he never saw the MRIs - nor has he chosen to submit
	   a report indicating that he has seen them since.
       10. I abstract from Dr. Fremed's correct quote from the
	   radiologist's report regarding the C-spine MRI given
	   on page 3 paragraph 3, an outlined form:

            i) C3-C4: osteophytosis resulted in mild right neural
                      foraminal compromise - without definite
                      exiting nerve root compromise.

           ii) C4-C5: similar to C3-C4 but with DEFINITE neural
                      foraminal compromise, RIGHT greater than left.

          iii) C5-C6: osteophytosis and broad-based BULGING disc
                      resulted in SEVERE encroachment of the right
                      neural foramen and likely exiting nerve root.

           iv) C6-C7: A BULGING disc and osteophyte 
                      compromises the right neural foramen.

                      SEVERE acquired central canal stenosis from
                      posterior osteophytosis and BULGING DISC

	   [Emphatic upper case mine]

	   The following are things that can be found by anybody
	   in any good anatomy book, of which I have had four for
	   almost twenty years:

	   a) Vertebra are classified as: Cervical, Thoracic, Lumbar
	      and Sacral, and numbered within each of these classes.
	      Vertebra numbers increase downwards toward the feet;
	      numbered exiting spinal nerves are named by the vertebra 
	      that are below their exit point.  E.g., the sixth cervical
	      nerve exits between vertebrae C5 and C6.

	   b) These nerves exit the spinal column through the
	      foraminal openings that are provided by the vertebrae
	      above and below.

	   c) Osteophytes are bony growths on bones, that have a
	      density less than real bone which is how they can
	      distinguished in radiologicals.

	   d) Osteophytes appear in radiologicals and unfortunately,
	      in human beings sometimes as a consequence of injury
	      and also simply in aging.

	   e) Injury at an osteophytic site can increase their growth
	      rate, even so, osteophytic growth is relatively slow,
	      over years.

	   f) Exiting Spinal Nerves have everything to do with
	      our senses of touch, temperature and pain, location
	      of body parts and motions of our body caused by
	      the neurally excited fibres of our muscles

	   g) There are areas of skin that are associated with the
	      spinal nerves called dermatomes.

	   h) The Nerves C4, C5, C5, C7, C8, T1 all enter into the
	      brachial plexus located in the general area of the
	      shoulder and upper arm.  This is one of nature's
	      redundancies in neural connection with important
	      muscles of the upper body.

	   i) From the interchange of the brachial plexus comes
	      the three major nerves (radial, medial, ulnar) of
	      the arm, and the axillary nerve serving the deltoid
	      muscle that caps the shoulder joint, as well as the
	      suprascapular nerve that serves the rotator cuff,
	      a set of muscles controlling the shoulder joint and
	      helping to hold it together.

	   j) An injury to the spinal cord can affect everything
	      below (caudal to) the point of injury; even slightly
	      above through vascular injury.

	   k) The spinal cord, like the brain has no supporting
	      internal structure and has a jelly-like consistency.

	   l) Neurons of the CNS do not regenerate effectively,
	      as neurons of the PNS can; physical damage to the
	      CNS is physically permanent.

       11. It is perfectly true that what may look scary in a
	   radiological study, may not be all that bad if the
	   the subject of the study is asymptomatic.

       12. Osteophytes and even bulging discs CAN be asymptomatic,
	   and not be result of injury.

       13. Dr. Fremed fails to make mention of the nature of the
	   MVA and its possible connection with the nature of my
	   injuries.  The nature of my injury, from how the car
	   actually moved is of a whiplash hitting the neck
	   in a maximally twisted configuration, and then torsional
	   (impact that rotated the car), torsional again as I
	   uncoiled to brace with my hand, a rebound driving
	   the humerus into the glenoid, and finally a more complex
	   motion involving compression as the car ran up onto
	   a retaining wall with one front wheel, which then
	   fell off the retaining wall.

       14. Bulging discs, as well as damage to ligaments, joints
	   and muscles are also possible results of such trauma.

       15. Nowhere in his declaration of documents, nor in his review
	   is there any mention of the contents of the police report,
	   or my deposition which have details of the MVA, consistent
	   with paragraph 13 here.

       16. Although Dr. Fremed freely quotes the C-spine radiological
	   report, including at iv) for C5-C6

                SEVERE acquired central canal stenosis from
                posterior osteophytosis and BULGING DISC

	   he fails to recognize, even after the fact, the possible
	   severity of this condition: a bulging disc is pushing into
	   the spinal cord, maintaining pressure on it and POSSIBLY
	   displacing it so pressure is then also being applied by
	   the osteophytes on the other side.

       17. Dr. Fremed denies the possibility of clinical significance
	   of the "severe acquired central stenosis", when: it is this
	   for which Dr. Haglund ordered surgery quickly; and when the
	   C-cord atrophy is at the location of this stenosis; and when
	   the expected symptoms of this atrophy are present, in a
	   disabling and painful reality.  Dr. Fremed's position is
	   an untenable one, contradicted by all evidence and history,
	   and as a neurologist, he should know that his denials
	   of serious and permanent injury to my C-cord are not
	   only fabrications, but fabrications that will cause me
	   further harm.

       18. Dr. Fremed does not note from Dr. Boulukos's reports that
	   there was a change in curvature of the neck after the MVA.
	   He also fails to note the possibility that this change which
	   was after the MVA might have assigned a new geometry to
	   osteophyte formations that then had them functioning to
	   cause foraminal compromises at C5-C7, nor does he remark on
	   the fact that foraminal encroachments and compromises
	   were all on the right side, and that this might seem a
	   little odd in the absence of trauma.

       19. Dr. Fremed fails utterly at even considering the possibilities
	   contained in clear consistency between objective radiologicals
	   and symptomatology, making his bias to his conclusion evident;
	   and even more so by systematically leaping to the phrase
	   "degenerative changes", while even there, having to make it
	   clear that these degenerative changes are not MVA related.
	   He uses the word "degenerative" twenty times in his review.

       20. In page 3 paragraph 1, Dr. Fremed keeps talking about
	   "osteophytic changes".  There are no changes observable
	   other than inferring that they are there now, and at some
	   time in the past, they were not.  There are only "osteophytes"
	   which would not have changed significantly, even in injury,
	   from the MVA on 09/16/94 to the MRI on 03/10/95.

       21. In page 3 paragraph 1, Dr. Fremed asserts
	   "These osteophytic changes however were again long standing
	   in formation in this 55 year old gentleman and in all medical
           probability were unrelated to the accident in question."

		a) I was 50 when the MRIs were taken;
	           as of 12/04/99 I am 55.

		b) Why is a neurologist speaking in the area of
	           a orthopedist or rheumatologist?

	        c) If he considers me a gentleman why is he so
		   vicious about me later on in his report?

	        d) Why would anyone even consider that an MVA
		   would cause osteophytes sufficient to cause
		   foraminal compromise within 175 days?

       22. In page 3 paragraph 2, Dr. Fremed recites correctly
	   the radiological report on L-spine MRIs, noting only
	   in paragraph 3 of the same page, "I reviewed the actual
	   films and agree with the presence of degenerative changes
	   as described above."  He then completely dismisses all
	   other findings in the report, including:

	   "Diffuse disc bulging was noted at L2-L3 and L3-L4 with
	    FLATTEN THE VENTRAL THECAL SAC.  Borderline mild acquired
	    central canal stenosis was noted at L2-L3 with minimal
	    encroachment on the lateral recesses but not the neural
	    [My upper case emphasis]

	    This, unfortunately engenders another small anatomy lesson
	    that can be gotten by anyone from a good anatomy text.
	    It's just fact, nothing controversial.

	    Intervertebral discs are held in place by a strong tendinous
	    sheath that attaches to the vertebra above and to the vertebra
	    below.  Translation of the first emphasis: the sheath has
	    broken, and the radiologist suspects that to be a consequence
	    of a vertebra not being in the alignment with others in which
	    it should be.

	    The uncovering of the disk has resulted in it being pushed
	    laterally so as to "flatten the ventral thecal sac".

	    The thecal sac is the membranous sac that encloses the spinal
	    cord together with the spinal fluid, the fluid carrying
	    essential nourishment and waste disposal for the cord.

	    If the sac membrane is flattened against the cord itself,
	    the spinal fluid is not able to reach that area of the cord,
	    and can cause cord damage since it is being starved of what
	    it needs to live.  If this condition is maintained, or if
	    even worse, the cord itself is being impinged upon by this
	    pressure, severe, permanent and irreversible damage to the
	    spinal cord can result.  The symptoms can be quite subtle
	    at first, or quite excruciating, or, in alternates,
	    depending on bodily positions or motions.

	    Dr. Fremed ignores this potentially dangerous and destructive
	    situation with a willful and reckless endangerment of my well
	    being, and, of course, with consistency to hammering home his
	    preordained conclusion, yet again, that "no injuries were MVA

       23. In page 3 paragraph 4, Dr. Fremed recites some subjective
	   reports repeated by Dr. Linder on 05/03/95 [erroneously reported
	   as "3/5/95"], that shows some improvement.
	   Those improvements were a consequence of confining myself to
	   bedrest and intensely cold icepacks and the general performance
	   of nothing.  They were certainly not permanent improvements,
	   as other medical records show.

       24. In page 3 paragraph 5, extending onto page 4, describes a
	   radiological report of an MRI of the right shoulder, which
	   would be consistent with both symptomatology as well as the
	   conditions of the MVA.  No comment from Dr. Fremed, except
	   that shoulder MRIs are "out of my area of neurological
	   expertise" [Personal note: they are confusing to me too]

	   Now begins Dr. Fremed's uncontrolled viciousness, first by
	   attacking the competence and integrity of my treating physicians,
	   and then by an series of ad hominem attacks on me, all such
	   attacks being completely groundless.

       25. In page 3 paragraph 5, extending onto page 4, last line,
	   the last sentence reads:

	   "Apparently Dr. Peter Boulukos, a chiropractor did not consider
	   ordering an MRI of the right shoulder outside his area of
	   chiropractic expertise."

	   It seems Dr. Fremed is not aware, chiropractors receive the
	   same education as physicians excepting pathology and
	   pharmacology.  In my many years of experience, while any
	   given physician or chiropractor may not be proficient at
	   reading certain kinds or types of radiologicals, which is why
	   we have radiologists as specialists, they are both perfectly
	   competent (with a few exceptions) at reading English and
	   understanding a radiologist's reports.  There is no reason
	   that I know, and by now I know Dr. Boulukos's talents, that
	   he could not read the report and understand how it might
	   correlate with given symptoms.  This statement of Dr. Fremed's
	   is an insult to a man of talent and integrity who meets my
	   rather demanding standards.  It may very well be libelous,
	   since there is no proof whatsoever to substantiate it, and
	   it is written in a public document that has been submitted
	   to an adjudicating body.

	   The simple fact is that from personal knowledge, this MRI
	   was specially ordered as a time saver, since he had referred
	   me to Dr. Schmaus, a physician, and wanted the MRI in my
	   hand at the time of that appointment.

       26. In page 4 paragraph 2, after inflationary recitation of other's
	   work, namely Dr. Schmaus in his report 06/26/95, Dr. Fremed
	   states that Dr. Schmaus diagnosed rotor cuff injury, failing
	   to note, as he most frequently does, the strong relation between
	   such a diagnosis and the particulars of the accident.

       27. In page 4, paragraph 3, Dr. Fremed cursorily dismisses a
	   report from Dr. Stabile, ending with, "There is no
	   description of any radicular pain down the arms or legs."

		a) This was not a full scale examination.

		b) Radicular pain down the legs, which some how
	           I have never experienced, and therefore never
	           complained of, is typically the result of L5-S1
		   radiculopathy resulting in sciatic involvement.

		c) Going back to the L-spine MRIs, the crucial
		   problem is the central stenosis at L4-L5.
                   "At L5-S1, disc bulging was noted as well with a
	           superimposed small disc protrusion and annular tear
	           central an to the right paracentral region effacing
	           the epidural fat but not deforming the thecal sac."
		   So, on radiological evidence L5-S1 compromise would
		   not be expected anyhow.  Why make the comment?

       28. In page 4 paragraph 4, Dr. Fremed describes a report from
	   psychologist Dr. Martin Kluger, "The patient sought psychological
	   treatment alleging that 'his emotional condition worsened
	   dramatically after the discontinuation of medical benefits
	   by State Farm Indemnity of New Jersey.  He felt unable to
	   cope with the new and added stress.'" Not only is his quote
	   from Dr. Kluger's report accurate, but it is also true.
	   In total contradiction to this statement, Dr. Fremed later
	   asserts, "It is evident from reviewing Dr. Hammel's deposition
	   testimony and medical records that he displays a tendency to
	   blame all of his problems occurring after the accident in
	   question on the accident,"  This comment, which is found in
	   his "IMPRESSION" is patently wrong, as evidenced by all the
	   records that he claims to have reviewed - and by the claims
	   of this action.

	   I do not blame "the accident", all of whose problems could
	   have been solved with no permanent injuries.

	   I blame and accuse the Defendants in this action including
	   Dr. Fremed as being responsible through their racketeering
	   activities, this very review by him for example, as being
	   responsible for the destruction of my body and serious enough
	   injury to Plaintiff Bellamente so as to render us both so
	   disabled that we are no longer capable of business or work,
	   nor even existence as individual human beings.

       29. Also on page 4 paragraph 4, "Dr. Kluger does not indicate
	   who referred this patient to him."

	   The statement has no business in any medical report or review.
	   So what?  Is this a crime?  If it must be known, I found
	   Dr. Kluger the same way I find all physicians, attorneys
	   or other professionals: through investigation and channels
	   of information available to me.  I have a rule of thumb:
	   Genius always recognizes and knows genius.  Find one and
	   you are linked into a network of genius and integrity.
	   The rule has served me well.

       30. Again on page 4 paragraph 4, "Dr. Kluger does not comment
	   on Dr. Hammel's apparent difficulty to maintain regular
	   employment commensurate with his academic credentials even
	   prior to the accident in question."

	   The statement has no business in any medical report or review.

	   Dr. Kluger does not comment on this because there was no
	   difficulty prior to the MVA; and where or how a nonexistent
	   could possibly be "apparent" to Dr. Fremed is beyond reason.

	   After the MVA, my businesses suffered.  With Defendants'
	   continuing patterns of racketeering, the abilities of
	   both Plaintiffs to maintain any sort of regular employment
	   or even to have any business or take care of themselves
	   properly and independently is nonexistent.  There is no
	   reason to expect that this situation will ever change.

       31. Dr. Kluger does state, however, "Since none of these factors
	   existed prior to the accident, I must assume that all of the
	   symptoms that he [Hammel] complained about are a direct result
	   of the accident." [Cf. Letter of June 8, 1996]  This is yet
	   another attribution that Dr. Fremed fails to note in his

       32. On page 4, paragraph 2, Dr. Fremed purports to review the
	   report of Dr. Schmaus dated 06/26/95.  While making a trivial
	   synopsis of subjective complaints, ignoring their severity,
	   Dr. Fremed completely omits any details of the actual
	   physical examination that begins in paragraph 3 of that
	   report.  This examination reveals genuine injury of a
	   traumatic pattern.  What Dr. Fremed states as Dr. Schmaus's
	   "diagnosis" is actually an "impression"; there is a difference.
	   Dr. Schmaus's "impression" is one of "rotator cuff injury".
	   Dr. Fremed fails to state how a rotator cuff injury can spring
	   to life suddenly without injury, or how it could appear
	   suddenly, without injury, as a result of chronic degenerative
	   disease, of which he seems so fond as simplistic explanation
	   for anything.

       33. Dr. Fremed claims to have records of Dr. Schmaus, and yet
	   completely ignores Dr. Schmaus's letter dated 10/18/95,
	   sent to the attention of Idiana Murray, which reads,

	   "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."

	   Dr. Fremed also fails to include in his review any mention
	   of Dr. Schmaus's Diagnosis of "Right Frozen Shoulder,
	   Right Shoulder Impingement" as well as the Prescription
	   for physical therapy which was denied me by SFI; and for
	   which I finally received some, now almost useless therapy
	   beginning September 15, 1997; this through Medicaid,
	   not SFI.  Dr. Schmaus's prescription was dated September 5,
	   1995.  Dr. Savatsky issued another prescription for physical
	   therapy on November 29, 1995.

	   These are yet more of the multitude of attributions of injury
	   to the MVA, both direct and indirect, all of which are absent
	   from Dr. Fremed's review.

       34. On page 4, paragraph 6, in discussing Dr. Savatsky's report,
	   Dr. Fremed once again fails to note the explicit attribution,

	   "The symptoms are the result of a motor vehicle accident
	   while bracing from impact." [referring to shoulder injuries]

       35. Continuing on to page 4, paragraph 7, Dr. Fremed purports
	   to synopsize a note by Rita Colvard made on 04/16/96.
	   This was a note made during a first intake meeting to begin

	   By juxtaposing and connecting just the right excerpts and
	   words, by innuendo, I now become, in this paragraph, the
	   image of some kind of drug addict.  Once again, what Dr.
	   Fremed omits from this note (which never should have been
	   released in the first place) is completely characteristic
	   of his fraudulent intent and unprofessional conduct, as
	   well as his motive to support SFI's denial of benefits
	   through fraudulent means.

	   What Dr. Fremed does not report is why I was, in fact, there.
	   The following which precedes the material from which Dr.
	   Fremed makes his fabrication explains why I was there.

	   Ms. Colvard writes, "Mr. Hammel reports no difficulties
	   whatsoever until he was injured in an automobile accident
	   September 16, 1994, with resulting spinal injuries.  He has
	   also had tremendous difficulties with the insurance company
	   [SFI] and other legal difficulties because the insurance
	   company will not pay on this, and it is a long-standing
	   problem in dealing with these issues.  He describes himself
	   as often becoming rageful as he considers this injustice
	   toward him, specifically, his anger is directed toward the
	   insurance company.  He relates his depression and anxiety
	   to what has happened to him."

       36. Again in page 4, paragraph 7, Dr. Fremed writes "Ms. Colvard
	   documents that while still in New Jersey that patient
	   had an EKG and was told of a left bundle branch block."
	   Why would he use this second hand information?  It is
	   a form of discrediting, when claiming to have Dr.
	   Sender's records which contain the EKG records that
	   very clearly indicate and say outright "LBBB" on
	   November 6, 1995, together with a diagnosis of
	   "severe anxiety".  While just before, on 10/30/95,
	   Dr. Sender, who had been my internist and GP for years
	   diagnosed PTSD, coupled with palpitations/skipped beats,
	   with BP of 146/80.  The records of Dr. Sender will also
	   show that my normal BP was 120/80 or lower.

       37. On page 5, paragraph 2, Dr. Fremed remarks that, "Notes
	   by C. P. Laub, apparently a counsellor at Smoky Mountain
	   Center were reviewed", but declines to recite anything
	   from them.  Mr. Charles P. Laub was, in fact, Counsellor
	   and also Director of the Smoky Mountain Center.  The
	   substance contained in these notes are reiterations and
	   continuances of the paragraph included in paragraph 31.
	   here, and one can understand why no comment is made
	   upon them.

       38. Though notes by Cheri Wright-Murphy were provided to
	   SFI, Dr. Fremed fails to acknowledge their existence.
	   They too continue with the paragraph in Ms. Colvard's
	   note quoted in 31. here, and again the reason for omission
	   is clear.

       39. Though notes analyses and diagnoses were made by
	   Dr. Mark Lawrence, a psychiatrist, and these were submitted
	   to SFI in their discovery in the NJ PIP action, they
	   are not even mentioned.  The Smoky Mountain Center
	   notes are so voluminous, that to quote them further here
	   would be foolish since they are attached as appendices to
	   this Memorandum.

       40. Before addressing the diatribe against Dr. Haglund, so that
	   psychological/psychiatric continuity is not lost, I want to
	   address the misplaced sentence at the opening of paragraph 4
	   on page 5, which simply says that "Records from Barbara
	   Dobrowski also of Smoky Mountain Center on 05/13/97 through
	   05/16/97 were reviewed."

	   SFI was provided, again through discovery, with records from
	   Ms. Dobrowski beginning on 09/12/96 through 04/30/97; she is
	   still my therapist and will remain so.  I have no idea how
	   Dr. Fremed came into possession of these 4 days of therapy
	   notes, but I would like to know.  In reading Ms Dobrowski's
	   notes as attached, it is easy to see the distinct and consistent
	   bias of Dr. Fremed displayed through trickery and deceit,
	   and exactly why these notes are not commented upon.
	   Perhaps this sentence in paragraph 4 on page 5 was supposed
	   to be hidden.  That would not be inconsistent with
	   the general patterns of deceit and unprofessional behavior
	   exhibited in Dr. Fremed's review.

       41. This is all the more to the point since the passing mention
	   of Ms. Dobrowski is literally stuck irrelevantly at the head
	   of a paragraph in the middle of Dr. Fremed's diatribe impugning
	   Dr. Haglund, my neuro surgeon at Duke University Medical Center.

	   That Dr. Fremed did not raise the question of who referred
	   me to Dr. Haglund is only that his first response was to to
	   Dr. Schmaus, which happens to be a vast but expedient
	   simplification of reality.  Both Plaintiff Bellamente and I
	   introduced Dr. Haglund to Dr. Schmaus.  We both seek genius,
	   especially when our lives are at stake.  It is a followed
	   axiom that genius will know and recommend genius, even in
	   another area.  We both knew Dr. David Adams referred by Dr.
	   Schmaus, and Dr, Robert C. Rubin to be a men of genius,
	   meticulousness and uncompromising integrity, so we asked them
	   for a recommendation for a neurosurgeon, on 04/11/96, at first,
	   for Bellamente's surgery.  We sought a neurosurgeon who should
	   be at Duke University Medical Center (DUMC), which was not only
	   in North Carolina, but known to us as one of four top ranking
	   hospitals for neurosurgery in the the United States.  They
	   recommended Dr. Robert Wilkins at Duke.  On contacting Dr.
	   Wilkins 06/06/96 he said he was going to retire in a few years,
	   and was sorry but he was not taking any more "insurance cases".

	   He did, however, recommend two of his brightest colleagues,
	   one of whom was Dr. Haglund.  Choosing between the two was
	   difficult, but we both decided that Dr. Haglund was our best
	   choice, based on impersonal criteria.  We are both still
	   very happy with that choice.

	   The point of this preface is that Dr. Haglund was chosen with
	   care by credentials and through professional recommendation
	   and reputation of a trustworthy nature; he was not chosen by
	   accident nor for any purpose other than his genius and supreme
	   craftsmanship as a neurosurgeon.  Since I have known and spoken
	   with Dr. Haglund from our first meeting on 08/26/96, I feel
	   competent as an observer to comment on his nature as physician,
	   scientist and his integrity.

	   Dr. Haglund is completely dedicated to what he does and has the
	   highest standards of excellence in his chosen work, which is as
	   neurosurgeon, professor of neurosurgery, and researcher in
	   neurology.  He has precious little time in reality, and precious
	   little time for the nonsense that is inflicted by insurance
	   companies, which interferes with the dedicated purpose of
	   his life.  Even as a neurosurgeon and diagnostician he is
	   truly both surgeon/physician and scientist.  His diagnoses
	   and attributions are not rendered lightly because of his
	   scientific integrity.

	   In his earlier notes, attribution of initial injuries to the
	   MVA of 09/16/94 will not be found because he is two years
	   removed from that date, so his inferences are qualified in
	   good scientific fashion.  He is communicative with me on
	   scientific, anatomical and surgical matters in medical
	   details of my condition because he now knows that I will
	   know what he is talking about, and that should I not, I
	   will ask for explanation and understand it.

	   Dr. Fremed has apparently not experienced the performance
	   pressure placed on a neurosurgeon at DUMC, and also has no
	   apparent personal knowledge of Dr. Haglund.  He refuses to
	   acknowledge, or tediously once again, consider the possibility
	   that Dr. Haglund may be overworked and unable to give time
	   to covering his flanks where the ilk of Dr. Fremed is on
	   the attack.  Dr. Haglund has always been honorable by both
	   Plaintiffs' experience, while honor is clearly lacking in
	   Dr. Fremed, again as evidenced by his two paper reviews,
	   one of which is analysed here, and his "IME" report on
	   Plaintiff Bellamente.

	   The interesting question is why Dr. Fremed is on the attack
	   against genius.  When confronted with such a situation that
	   is seemingly inexplicable, the abstract question I ask is
	   simply, who has what to gain from whom?

	   Dr. Fremed must attack Dr. Haglund, no matter the disparity
	   in their credentials, because he will be rewarded handsomely
	   by SFI for doing so.  This behavior though aberrant for a
	   physician, is extremely lucrative.  Dr. Fremed was paid $600
	   for a 15 minute perfunctory "IME" on 07/25/95 which resulted
	   is a 6 page single spaced, small type report that was used
	   by SFI to deny all neurological benefits.  On the basis of
	   his ability to have claims dismissed he has unjustly enriched
	   himself.  By contriving to have claims dismissed using the
	   very same tactics exposed here, he has unjustly enriched
	   himself, by engaging, willfully, in SFI's patterns of
	   racketeering that are called "claims handling".  He has
	   also deliberately injured those claimants, misusing his
	   SFI given authority, and alleged expertise and professionalism
	   as a weapon in SFI's war of fraud, extortion and robbery on
	   its own policy holders.

       43. Now, addressing Dr. Fremed's diatribe against Dr. Haglund:
	   Unfortunately, I will be quoting Dr. Fremed extensively.
	   On page 5, paragraph 3 of his review, Dr. Fremed begins, " Dr.
	   Hammel was evaluated by Dr. Michael Haglund, a neurosurgeon
	   at the Duke University Medical Center Clinic on 8/26/96.  He
	   indicates that Dr. Hammel was reaching back to get some paper
	   work when his car was struck from behind.  He commented that
	   originally after the accident 'everything was OK but that
	   evening he noted a stiff neck and severe upper arm pain.  He
	   had similar pain down the left arm and he also had bilateral
	   leg pain radiating to his thighs and into a four dermatomal

	   Dr. Fremed omits the description in Dr. Haglund's report of
	   the impact situation that classically gives rise to a
	   whiplash injury.  Dr. Fremed would not want to raise the
	   suspicion that injuries did, in fact, arise from the MVA,
	   since his conclusion to the contrary could not reasonably
	   be reached.

       44. Dr. Fremed continues quoting, "The patient complained of
	   spasms in his legs and pain in his arms involving all 10
	   digits of the hands but said that mainly the pain stayed
	   in his neck and arm area and radiated to the middle three
	   digits.  He denied lower extremity paraesthesias or bowel
	   or bladder problems."

	   Fremed then states:

	   "Dr. Haglund reviewed MRI films [of 03/10/95] showing multilevel
	   stenosis and degenerative disease including foraminal narrowing
	   and retrolisthesis.  Dr. Haglund recommended proceeding with
	   surgery in the cervical region involving a C3-C6 laminectomy and
	   foraminotomies and then performing lumbar decompression 4 to
	   6 weeks later."

	   Dr. Fremed omits Dr. Haglund's concern in scheduling surgery as
	   soon as possible by writing in his clinic note of 08/26/96
	   "Surgery will be performed on September 25, 1996."
	   Surgery was attempted to be moved up to September 18, but
	   had to be put back to the 25th due to a hurricane.
	   Fremed also fails to note that for this scheduled surgery,
	   both Plaintiffs traveled 654 miles in pain and agitation by car.

	   This trek turned out to have the sole purpose of learning
	   that this very necessary surgery had been denied by both SFI
	   and SFM, despite the valiant efforts by Ms. Joanne Johnson,
	   of DUMC's "insurance department" to convince both SFI and SFM
	   of the necessity of surgery.  Dr. Fremed knows this, or
	   should know of it, since it is contained in my deposition
	   transcript, which he claims to have reviewed.

       45. Dr. Fremed goes on, "His [Dr. Haglund's] note establishes
	   no causal relationship between the need for this surgery
	   and the accident in question."

	   This is a stupid remark.  This note was made during a first
	   consultation with Dr. Haglund.  It was two years after the
	   MVA.  Dr. Haglund had not had time to review the voluminous
	   documentary records.  Such a statement would have
	   been foolhardy coming from an eminent neurosurgeon and
	   neurologist at Duke University Medical Center.  A statement
	   of attribution by Dr. Haglund at that time would not have
	   been reasonably possible.  Dr. Fremed's remark actually, in
	   logic, reduces to the fact that Dr. Haglund is a good
	   scientist and not an idiot.

       46. Dr. Fremed goes on further, "A subsequent note however, to
	   the patient's attorney dated 10/22/96 indicates that it was
	   his opinion that the accident exacerbated a pre-existing

	   "It appears that he based this on Dr. Hammel's subjective
	   complaints which by history began after the accident in
	   question.  He concluded 'the MVA seems to have played a
	   key role in causing the patient's current pain and syndrome.'"

	   This letter by Dr. Haglund of 10/22/96, was a response to a
	   letter from my attorney, answering questions, once again,
	   on the basis of his current knowledge, and is two (2) months
	   after his initial examination, during which time he had the
	   opportunity to review the complete medical file that was
	   made available to him on 08/26/96, and see the continuous line
	   of medical treatment leading from the MVA to seeing him, and
	   also to connect the opinions of treating healthcare givers
	   in sequence.  As time progresses Dr. Haglund accumulates
	   knowledge concerning my conditions and is therefore more and
	   more able to refine his medical opinions based on substantive
	   and professionally garnered evidence.  There is nothing strange
	   about this, yet Dr. Fremed would attempt to make it appear so.

	   Dr. Fremed's makes no effort to substantiate his claim that
	   "It appears that he [Dr. Haglund] based this on Dr. Hammel's
	   subjective complaints ..." Dr. Fremed's claim is, in fact,
	   insubstantiable, and contradicted by Dr. Haglund's letter.
	   Dr. Fremed completely distorts this letter to his own ends.
	   The second paragraph of Dr. Haglund's letter reads in its

		"In these situations, the MVA is either directly the
		cause of all of his [Hammel's] problems; exacerbates a
		pre-existing degenerative condition; or is not involved
		at all in his condition.  In Mr. Hammel's case, I would
		say it is a situation where the accident has exacerbated
		a pre-existing degenerative condition.  His MRI shows
		multilevel stenotic disease in the cervical region which
		likely was present before the accident but not causing
		him any difficulties.  Therefore, the accident would have
		exacerbated a pre-existing condition and did cause
		according to the patient and from my examination since
		the pain began at the time off the accident, the pain
		syndrome that he now has in his cervical lumbar region.
		Therefore, the MVA seems to have played a key role in
		causing the patient's current pain syndrome."

	   Dr. Haglund also based his decision for surgery on the cervical
	   MRIs of 03/10/95, which Dr. Fremed claims not to have, and was
	   in a position to know the situation with far greater detail.

       47. Dr. Fremed continues with, "He [Dr. Haglund] does not
	   indicate that the accident had any role in causing the
	   patient's considerable degenerative changes."

	   First, nowhere in Dr. Haglund's clinic note of 08/26/96, nor in
	   Dr. Haglund's letter of 10/22/96, nor in the MRI report of
	   03/10/95 is any degenerative condition referred to as
	   "considerable".  It is impossible to imagine how, when Dr.
	   Fremed denies his access to the actual MRIs taken on 03/10/95,
	   he could add this modifier with any logical basis.  The
	   insertion of this modifier "considerable" is a fabrication
	   whose design is fraudulently to support his untenable

	   Second, and as to Fremed's sentence as a whole, why, yet again,
	   would Dr. Haglund, physician and scientist, make such a patently
	   idiotic assertion?

       48. Dr. Fremed continues with Dr. Haglund's clinic note of
	   08/26/96, "On physical examination Dr. Haglund noted some
	   weakness in the biceps and triceps with positive straight
	   leg raising at 30 degrees on the right and 45 degrees on the
	   left.  He does not comment whether the straight leg raising
	   test was performed in both the supine and upright positions."

	   Dr. Fremed does not explain any clinical or neurological
	   significance to this remark, nor was he performing the
	   examination; it might be reasonably conjectured, once again,
	   that Dr. Haglund is not an idiot, has either explored what
	   he felt to be an appropriate avenue and found it unremarkable
	   or insignificant, or that this avenue of investigation did
	   not answer the questions he wanted answered.  This remark of
	   Dr. Fremed's is an inappropriate impugnation of Dr. Haglund's
	   considerable competence. 

       49. Dr. Fremed continues, "He [Dr. Haglund] did comment on
	   subjective complaints of decreased pinprick in an L3-L4 and
	   slight L5 distribution with corresponding decrease in
	   temperature perception.  The patient also reported decreased
	   pinprick and temperature in the C5-C6 dermatome with normal
	   vibration and touch.  Reflexes were described as diminished
	   in the triceps and knee.  Toes were downgoing and Hoffman's
	   sign was negative.  Cerebellar and Romberg's testing was normal."
	   The emphasis on "subjective complaints" is nothing more than
	   an attempt now to impugn my integrity, again, baselessly.
	   Many, if not most neurological tests are of a subjective
	   nature.  A good neurologist, which Dr. Haglund happens to be,
	   is perfectly capable of discerning a pattern, or lack thereof
	   through the redundancies of tests.  Dr. Fremed is aware, one
	   hopes, that reflexes are not subjective.

       50. Continuing with page 5, paragraph 4, which extends to
	   page 6,  Dr. Fremed writes, "I note that Dr. Hammel was
	   admitted to Duke University Medical Center on 5/13/97 through
	   5/16/97."  So far, detailed accuracy.  "They document a past
	   surgical history of an extensor digitorum release [1981 -wch]
	   and deviated septum repair [as a teenager, and not due to any
	   trauma - wch].  If any other records documenting any prior
	   trauma in this patient become available, I would be happy to
	   review them and issue a supplemental report if indicated.

	   One could ask of Dr. Fremed, "prior to what?"  He is completely
	   ignoring the trauma sustained in the MVA of 09/16/94.

	   But, of course, he would be happy, then being able to twist
	   some new form of "degenerative disease" or trauma to be the
	   cause of any injuries - that cannot, under the ukase of SFI be
	   allowed.  The unwarranted assumption that he would hope to
	   get away with is that these conditions were the result of trauma.
	   As it turns out, the extensor digitorum release was the result
	   of mild trauma, and the correction would only have been
	   important to a pianist.  The deviated septum had no traumatic
	   basis, and yet, Dr. Fremed implies that it was, with no basis
	   or knowledge.

       51. Fremed:

	   "The patient during that admission underwent a C-3 through
	   C-7 posterior laminectomy and did well postoperatively."

	   Date 05/13/97 was the actual date of surgery.  What must be
	   kept in mind is that the original proposal was not the quintuple
	   laminectomy that was performed, but that Dr. Haglund proposed
	   a quadruple laminectomy for me on 08/26/96, and had it scheduled
	   as soon as possible on 09/25/96; and that both SFI and SFM
	   had refused authorization for this.  The medically necessary
	   surgery was delayed 230 days, and would still not have been
	   performed but for Medicaid, acquired through disability (SSI).
	   These were the second and third denials of medically necessary
	   surgery, which Dr. Fremed refuses to acknowledge, as he does
	   with the first denial of all medical PIP benefits.

       52. Fremed:

	   "His [Dr. Haglund's] principal diagnosis was cervical stenosis."

	   This is particularly interesting since in Dr. Haglund's decision
	   for the correctness of surgical intervention was based on the
	   very MRIs of 03/10/95, discussed in paragraphs 8-18 herein,
	   which Dr. Fremed has conveniently not seen, and yet which contained
	   enough information to cause Dr. Haglund enough alarm to schedule
	   surgery as soon as possible.  The central stenosis, as a dangerous
	   condition, was clearly present in the 03/10/95 radiological
	   report, for Dr. Fremed to attempt to wave away its past emergent
	   importance is simply unconscionable.

       53. Fremed:

	   "The operative report describes laminectomies at C3, C4, C5, C6
	   and C7 with bilateral foraminotomies especially at C5-C6."

	   Quite obviously things were worse, or had become worse than
	   Dr. Haglund had anticipated.  In fact, Dr. Haglund's words,
	   written down, verbatim, by Mr. Bellamente immediately after
	   my surgery were

		"[His] muscles were very messy and uneven - therefore [the
	         surgery was] more bloody - [we] took off [all the] bone
		 [and the] ligaments were weak, but now weaker.
		 hard collar on drive.  Get him up slowly. 15% first
		 nite then more - special attention to be paid to signs
		 of neck drooping or weakness."

	   This type of injury, speaking from the viewpoint of a
	   physicist who happens to have studied and knows gross
	   anatomy, is perfectly consistent with the kind of torsional
	   insult that did happen, which again is consistent with
	   known motions of the automobile after impact in the MVA
	   of 09/16/94.

       54. Fremed:

	   "No reference is made in the operative report to any disc
	   herniation or nerve root impingement."

	   For this, there is good reason, and Dr. Fremed is simply
	   playing games.  The C-spine radiologicals of 03/10/95 did
	   not, in fact, show herniations of any discs, there were
	   none; why should one comment on something nonexistent and
	   not expected.  To suggest that one one should, elicits a
	   string of words not proper in a document presented to a
	   U.S. District Court.


       55. On page 6, paragraph 2, Dr. Fremed states in his review,
	   "Postoperative notes from Dr. Haglund dated 6/23/97 describe
	   a good postoperative course with almost complete relief of
	   pain and tingling in his hands.  Dr. Haglund indicated
	   'as I noted at the time of the operation, he did have a lot
	   of muscle disruption suggesting a previous trauma to his neck'
	   I note that the operative report makes no reference to any
	   muscle abnormality"

	   Perhaps, 41 days after my surgery, Dr. Haglund has actually
	   confused what he wrote with what was directly spoken to
	   Plaintiff Bellamente immediately after surgery.  Yet he
	   remembers the oddness of it and is remarking on it in his
	   notes of 06/23/97.  A glance at the operative report of one
	   page shows that it hurriedly conceived, lacking in finery
	   of details, and merely reports the basics of what was done,
	   and that the surgery had no major complications.  A possible
	   error in this regard does not make Dr. Haglund a liar,
	   as Fremed would imply.

       56. Dr. Fremed further complains, "Dr. Haglund does not further
	   explain what he means by 'muscle disruption'."

	   Perhaps because no one (except me) asked and under the
	   circumstances, he thought that sufficient a description for
	   the complicated experience of seeing what was actually
	   there, a perspective that only Dr. Haglund, and certain
	   other OR personnel had.

       57. Fremed, at page 6, paragraph 3:

	   "Dr. Haglund's note of 5/11/98 describes complaints of a
	   burning sensation in the hands with decreased coordination.
	   At that point he apparently was on Neurontin and was having
	   increasing problems with activities of daily living.  He
	   described trouble walking and some weakness.  He complained
	   of constipation and losing urinary control.  On examination
	   his motor strength was 5-/5 throughout with some giveaway
	   strength as well as decreased pinprick in the C7 distribution
	   more on the left than the right.  He had diminished vibratory
	   sensation in a stocking-like distribution in the feet.
	   He underwent an an EMG on 5/11/98 which according to Dr.
	   Haglund showed no evidence of any peripheral neuropathy.
	   DESPITE the normal EMG nerve conduction study Dr. Haglund
	   suggested that the dysfunction of the hands and feet "go
	   along clearly with some type of traumatic injury and the
	   degeneration of the spinal cord itself."

	   [Emphatic upper case "DESPITE" mine]

	   I have no idea what Dr. Fremed is trying to pull here.
	   The facts of life are that the nervous system is conceptually
	   and structurally divided into the Central Nervous System (CNS)
	   and the Peripheral Nervous System (PNS).  The EMG study showed
	   no peripheral neuropathy in limbs, so the only place left to
	   look is the CNS.  Radiculopathy (PNS) which would show in EMG
	   did not show.  EMGs do not measure neural conduction in the
	   CNS. The process of refining diagnoses is successively to rule
	   out.  In medical science as in any science, there is no way to
	   prove a hypothesis or diagnosis.  There was a documented
	   traumatic injury, namely the MVA.

	   The fact that this initial injury was deliberately
	   and maliciously not permitted to be attended to by decompression
	   back in the fall of 1995 has caused, by maintaining pressure
	   on the C-cord, axonal deaths, cell deaths and well as vascular
	   injury resulting in C-cord atrophy.  Or, as expressed in Dr.
	   Haglund's more terse letter of May 19, 1999, "As I have
	   stated ... the atrophy of his [Hammel's] spinal cord was
	   exacerbated by the MVA and further compromised by delaying his
	   cervical decompression."

	   There is nothing particularly difficult about this, yet Dr.
	   Fremed seems to lack the understanding of that which is
	   intuitively obvious even to the undiscerning student.
	   With this level of intelligence, Dr. Fremed would never have
	   made it through medical school, yet he did.  The resolution to
	   this apparent paradox is once again that Dr. Fremed's review
	   is a fraudulent sham, and a desperate and wanton attempt by
	   any means at his disposal to warp reality to his own ends,
	   which also happen to be the ends of SFI and its attorneys.

	   The scientifically conservative nature of Dr. Haglund's
	   opinions should be noted in the extract two paragraphs above
	   from his letter of May 19, 1999.  He does not know and cannot
	   know exactly when the compression of the C-cord began, and so
	   does not assert that the MVA caused it, even though that may
	   actually be the case.  On this exact point, no evidence of
	   any C-cord atrophy has ever been remarked upon in the MRIs
	   of the cervical spine 03/10/95; no C-cord atrophy is noted
	   in the radiological report on those MRIs.  These MRIs were
	   taken shortly after the MVA of 09/16/94.  From this it is
	   not unreasonable to assume that had decompressional surgery
	   taken place then, as Dr. Haglund has said it should have,
	   that no C-cord atrophy would be present now.

	   This is consistent with Dr. Haglund's contention that delay
	   has significantly exacerbated the atrophy.  Neither the MRIs
	   of 03/10/95 evidencing no atrophy, nor the MRIs of 09/08/97
	   evidencing C-cord atrophy were taken with contrast.

       58. Fremed:

	   "He does not support this conclusion with any more specific
	   description of what type of traumatic injury caused these
	   symptoms nor does he document any radiographic evidence of
	   spinal cord atrophy or degeneration."

	   Cf. inter alia, MRI report, both cervical and lumbar,
	   dated 09/08/97, wherein can be read,

	   "Atrophy of the mid-cervical spinal cord is identified, ..."
	   It is part of my medical records at DUMC, and attached here.

       59. Fremed:

	   "He suggested that the patient be considered for 25% cervical
	   impairment with some long tract signs.  His report however,
	   does not document any long tract signs and in fact commented
	   on previous examinations that the patient's toes were downgoing
	   and Hoffman's sign were negative."

	   Nor does he define "cervical impairment", or address total
	   body impairment.  The EMG report 05/11/98 from the study
	   documents "1 year history of difficulty walking and
	   dysaesthesias in upper and lower extremities, right greater
	   than left."  Dr. Adams neurological report indicates
	   L'Hermitte's sign, proprioceptive problems with feet.
	   Various neurological testings have demonstrated abnormal
	   reflexes of the extremities.  Other reports contain
	   specific observations of muscular weakness and atrophy.

       60. Fremed:

	   "Clearly Dr. Haglund's conclusion is entirely
	   inconsistent with his physical examinations."

	   What is clear is that Dr. Fremed is accusing Dr. Haglund of
	   being either incompetent or a liar.  Given the nature of this
	   purported review by Dr. Fremed, as exposed here, there is nothing
	   that could support either hypothesis.  In either case, it is
	   inappropriate, unprofessional and utterly unclear as to how
	   Dr. Fremed could say such a thing logically.  Dr. Fremed's reason
	   for saying it, however, is quite clear: this is a sham report
	   designed to rationalize, badly, his final conclusion at which he
	   seeks to arrive through techniques that include rabid ad hominem
	   attacks, and perfectly outrageous libelous statements.

       61. Fremed:

	   "I reviewed the actual EMG nerve conduction report and note
	   that the examiner described this as a normal study."

	   Which is to say CNS damage is indicated, absent neurological
	   diseases: MS, ALS, etc. which have been ruled out by physicians
	   of more than competence.  Tests for these are by spinal tap,
	   and both Drs. Haglund and Adams reassured me that there was
	   nothing to indicate that I should have such tests.

       62. Fremed page 6, paragraph 4:

	   "When seen by Dr. Haglund on 10/19/98, he had continued
	   complaints of burning in his hands interfering with various
	   activities and instability with walking.  Dr. Haglund indicates
	   that he discussed the patient's spinal cord degeneration and
	   myelomalacia that occurred because of his compressive syndromes
	   and said that these could be either compressive or vascular.

	   I once again point out that I have no record of any cervical
	   MRI scan showing or operative report documenting
	   any spinal cord degeneration or myelomalacia."

	   Dr. Fremed seems to have the strange notion that if he has not
	   seen something that is doesn't exist, or once again that Dr.
	   Haglund is a liar.  From here on, the transparency of Dr.
	   Fremed's fraud concerning his attack on Dr. Haglund should
	   be complete, so I will let it speak for itself.

       63. Fremed page 6, paragraph 4:

	   "I do note that Dr. Haglund considered these alleged findings
	   either compressive or vascular apparently making no reference
	   to any contribution from the alleged trauma."

	   See 58. here.

	   "He said the patient was going to see a urologist for erectile
	   dysfunction and trouble with urination."

       64. Fremed page 7, paragraph 2:

	   "A letter from Dr. Haglund to the patient's attorney,
	   dated 11/20/98 again makes reference to a 25% permanent
	   partial impairment rating for cervical impairment
	   with long tract signs."

	   "I again point out that Dr. Haglund's note fail to
	   document any long tract signs."

	   "He added 'I believe he has myelomalacia of the
	   spinal cord which was exacerbated significantly by the MVA.'"

	   "I once again note
	   that no radiographic study ever showed any myelomalacia
	   nor does Dr. Haglund indicate why he felt a single cervical
	   sprain or whiplash injury was playing a
	   significant role in this patient's cervical degenerative
	   disease which clearly
	   was long standing and many years in formation."

	   "He felt that the patient's
	   condition could either get worse or stabilize over time."

	   "A follow-up note of
	   May 19, 1999 reiterated his opinion that 'the atrophy of his
	   spinal cord was exacerbated by the MVA and further compromised
	   by delaying his cervical decompression.'"

	   "Once again, should any radiographic reports or films documenting
	   any atrophy of the spinal cord become available. I would be happy
	   to review them and issue a supplemental report if indicated."
       65. Fremed IMPRESSION:

	   "Review of the extensive records provided, reveals chronic
	   degenerative disease in both the cervical and lumbar regions
	   in this patient which in all medical probability predates
	   the accident in question."

	   That Dr. Fremed can find nothing but "degenerative disease"
	   in the totality of medical records, and can ignore completely
	   all that he does ignore is so preposterous that it simply
	   makes the conclusions of this analysis all the more obvious.

       66. Fremed IMPRESSION:

	   "The cervical degenerative disease could explain Dr. Hammel's
	   neck, arm and finger complaints which I note improved
	   following surgery."

	   The improvement after surgery, may have been real or even
	   a placebo effect.  Even I don't know the answer to that, and
	   it's my body and psyche.  The picture is the total body,
	   and that is one of muscular atrophy, as documented by physicians
	   and not simply my "subjective complaints".

	   The overall general problems can also be explained by MRI
	   documented mid C-cord atrophy.

       67. Fremed IMPRESSION:

	   "The surgery relieved neural foraminal stenosis caused by years
	   of chronic degenerative change unrelated to the accident in

	   Dr. Fremed denies having seen the original 1995 cervical MRIs,
	   denies having any evidence on MRI (although there are a few)
	   of C-cord atrophy, and so comes to this conclusion, we suppose
	   by divine inspiration.

	   Dr. Haglund saw the fundamental problem as a central stenosis:
	   the C6-C7 disk was pushing into the spinal cord itself, and
	   he had a perspective that Dr. Fremed denies, which is looking
	   at the actual MRIs.

	   Dr. Fremed is grasping at straws to say or fabricate anything
	   so he can "in his professional opinion", however untutored,
	   whatever - is not a result of the accident.  Well - some things
	   are not caused by the accident.  Some are caused by racketeering,
	   fraud, extortion, robbery, professional misconduct, and
	   other assorted criminal actions and torts of racketeering

       68. Fremed IMPRESSION:

	   "Dr. Haglund's references to myelomalacia, spinal cord
	   atrophy, and long tract signs in letters to the patient's
	   attorney are simply unfounded based on his notes which fail
	   to document any long tract signs on examination and which
	   fail to include any radiographic evidence of spinal cord
	   atrophy or myelomalacia."

	   That Dr. Fremed has not been provided by his co-conspirators
	   with the appropriate medical information is not to be blamed
	   on Dr. Haglund.  One generally doesn't wrap up a handy MRI
	   plate in a medical report.  But, then, Dr. Fremed knows that
	   very well.  The ice upon which he treads is about one
	   molecule thick.

       69. Fremed IMPRESSION, page 7, paragraph 3:

	   "It is evident from reviewing Dr. Hammel's deposition
	   testimony and medical records that he displays a tendency
	   to blame all of his problems occurring
	   after the accident in question on the accident."

	   It is not evident to me, and is not true; what I have blamed,
	   once discovered, is the patterns of racketeering engaged in
	   by my erstwhile insurance company State Farm Indemnity, their
	   employees, their attorneys named elsewhere, and last but not
	   least, certain prostitute physicians whose function it is to
	   conspire with SFI and its attorneys to inflict calculated harm
	   on already injured policy holders.  Dr, Fremed is one of these
	   prostitute physicians, about whom I have previously complained.

       70. Fremed IMPRESSION:

	   "He appears to believe that his inability to maintain employment,
	   his heart attack, his need to move to North Carolina,
	   his emotional complaints, and need for surgery were all the
	   result of the accident in question."

	   To the contrary; see response in the previous paragraph.

       71. Fremed IMPRESSION:

	   "This post hoc ergo propter hoc argument is simply fallacious."

	   Dr. Fremed's predicate is wrong as just explained.  However,
	   there is enough evidence that injury was done by the MVA,
	   and that had it been repaired when it's nature was discovered
	   that no permanent injury or harm of any kind would have
	   resulted.  Repair was deliberately made impossible by
	   SFI, and by SFM to whom the claim was inexplicably transferred.
	   This impossibility and the attendant profit schemes of
	   the defendants in this action is the source of all injuries
	   to the Plaintiffs complained of in this action by Plaintiffs.

       72. Fremed IMPRESSION:

	   "By history he suffered a cervical sprain which would
	   have been expected to resolve with time."

	   Dr. Fremed has never examined me nor seen me.  He has seen
	   only papers and an MRI or two, although not crucial ones.
	   What I actually suffered is beyond his knowledge.  What "would
	   have been expected" is not within his purview to say.

       73. Fremed IMPRESSION:

	   "Furthermore, his chronic degenerative disease in both the
	   cervical and lumbar spine would have been expected to
	   progress with time even in the absence of any additional

	   Dr. Fremed has no idea of any rate of degeneration of my
	   anything, if, indeed, there is any current progression as
	   witnessed by his failure even to make an estimate as to
	   any time within which any symptoms might be experienced; and
	   again what "would have been expected" is not within his
	   purview to say.  There is no objective evidence in existence
	   to support Dr. Fremed's claims.  That seems to be perfectly
	   consistent with the rest of his medical claims.

       74. Fremed IMPRESSION. page 7, paragraph 4:

	   "It appears in reviewing the above records that Dr. Hammel
	   viewed any physician or for that matter any attorney who did
	   not agree with his views of the accident being the cause of
	   all of his problems was incompetent or inappropriate."

	   This very statement, so wonderfully incompetent and
	   inappropriate in itself, is the summation of Dr. Fremed's venom.

	   I have no "view of the accident" except that which I perceived.
	   There didn't happen to be any physicians or attorneys around at
	   the time of the MVA.  So, I pretty much have a monopoly on what
	   I perceived.  Dr. Fremed's statement applied to me, seems by the
	   nature of his review, to apply more to him than to to me.
	   In my communications with SFI, when I declined a physician as
	   IME examiner, I politely said that they were "unacceptable" as
	   one can see nicely documented in SFI's internal notes.  I
	   thought this a more gentle thing to say than "known medical whore".
	   The now infamous MVA of 09/16/94 has nothing to do with
	   evaluations of people.  My physicians, psychotherapist and even
	   my current attorney tell me things I really don't want to hear.

	   They sometimes disagree with my views on various things;
	   sometimes I even get to be right.  Nevertheless, these people
	   are still my physicians, psychotherapist and attorney because
	   they are possessed of extraordinary intelligence, humanity and

	   My views as to anyone's incompetence in anything are determined
	   by pertinent facts, and my value judgments are mine to make for
	   myself, acting on those judgments, without necessarily speaking
	   them, with accountability for my values to no one.  I try never
	   to rely on the untested opinions of others, regardless of their
	   areas of expertise.

       75. Fremed IMPRESSION. page 8, paragraph 2:

	   "As commented above, should the actual cervical spine MRI
	   films become available, I would be happy to review them and
	   issue a supplemental report if indicated.  The same is true
	   for any other medical records that may come to light."

	   For another fee that will be internally charged against my
	   PIP protection.

       76. Fremed IMPRESSION. page 8, paragraph 3:

	   "It is my conclusion based on the medical records reviewed
	   thus far however, that Dr. Hammel suffered no permanent
	   neurologic injuries as a result of the accident in question
	   and that his cervical surgery was not necessitated by the
	   accident in question."

	   It is my conclusion, based on his review, and prior knowledge,
	   that Dr. Eric L. Fremed demonstrates such skill in fraudulent
	   medical reports, that he must have had quite a bit of practice
	   in his racketeering engagements with insurers, and that as
	   such he should probably be declared a public menace, never being
	   permitted to practice medicine, anywhere, ever again.

	   What completely gives him away here is the vengeful way in which
	   he attempts to arrive at his conclusion.  I allege that Dr.
	   Fremed has read and may still even have in his possession a
	   document passed on to him which is Exhibit B of the attached
	   complaint.  On Pages 6-10 of that document I dissected Dr.
	   Fremed's IME report on Plaintiff Bellamente against the medical
	   opinions of 4 treating physicians: two neurologists, one
	   neurosurgeon and one orthopedic surgeon, all of whom
	   explicitly disagreed with Dr. Fremed.  Dr. Fremed, has failed
	   to acknowledge, as Plaintiffs have only recently discovered
	   on 01/11/2000, that he has, in fact, read this document.
	   He does however admit it, on page 8 of a review of Plaintiff
	   Bellamente's "medical records" dated 06/14/99.  Dr. Fremed
	   fails, however, despite this complaint's length to say so
	   much as one word about it.  In particular, he fails to rebut
	   one statement from it, including the careful documentation
	   of all his crafty omissions from medical and radiological
	   reports.  Moreover, he also admits that Ms. Wall of Melli
	   Guerin & Wright provided a copy of that complaint to him.

	   Despite the expressed disagreement of Drs. Adams, Rubin,
	   Pojedinec and Jotkowitz with Dr. Fremed. SFI quite literally
	   used Dr. Fremed's report as a tool to deny Plaintiff Bellamente
	   medically necessary surgery.

	   Nonetheless, this purported "review" by Dr. Fremed of my medical
	   reports and records is my punishment for having the audacity to
	   say what is true about what he does.  In attempting to punish me,
	   he does again what he has done before in the IME report on Plaintiff
	   Bellamente.  Yet twice again now, when SFI, frantic in it's desire
	   to deny legitimate claims, and also to punish both Plaintiffs,
	   has used Dr. Fremed for similar "paper reviews" of Plaintiff
	   Bellamente's medical records, to come to a remarkably similar
	   conclusion by using the very same tactics of fraud,
	   deceit and trickery.

	   Now, however, SFI would like to reach back into the 1992
	   accident suffered by Plaintiff Bellamente alone to blame his
	   his injuries on that accident, as shown in Dr. Fremed's reviews
	   called rather pompously and inaccurately by Ms Wall "Narrative
	   Reports" of Plaintiff Bellamente's medical records dated
	   06/14/99 and 12/23/99.


	1) Fails to include in his review any attributions whatsoever
	   of initial injuries by treating physicians although they
	   were present in the reports of

		a) Dr. Boulukos in every Attending Physician Report
		   submitted to SFI

		b) Dr. Linder Twice on 02/16/95, 05/03/95

		c) Dr. Schmaus 10/18/95

		d) Dr. Kluger 06/8/96

		e) Dr. Savatsky 11/29/95

	2) Fails to include in his review any attributions of serious
	   and permanent injuries by Dr. Haglund to SFI's denial and
	   delays, in which they persist to this day.

	3) Fails to consider the known and well documented simultaneity
	   of initial injuries coincident with the MVA.

	4) Fails to consider the continuous line of medical treatments
	   from the MVA to the current day.

	5) Fails to acknowledge the serious and permanent injuries
	   resulting from SFI's denial and delays.

	6) Wantonly ascribes, arbitrarily, all injuries to a common
	   pre-existing "degenerative disease", considering nothing
	   else as even possible, despite the voluminous documentation
	   and opinions of actual treating physicians.

	7) Wantonly, and without foundation, in essence calls Dr.
	   Haglund a liar, and impugns his intelligence.

	8) Repeatedly inserts comments and opinions that are completely
	   inappropriate in a medical review.

	9) Systematically attempts to discredit and impugn, with no
	   substantive bases whatsoever, the integrity, intelligence,
	   competence and sanity of Plaintiff Hammel as well as his
	   treating physicians.

       11) Fails to admit in his review of my medical records
	   dated 06/30/99, what he already admits in his review
	   of Plaintiff Bellamente's medical records dated 06/14/99,
	   page 8, that he had read my severe criticism and allegation
	   of fraudulence of his IME report on Plaintiff Bellamente
	   in a complaint written to the New Jersey DOI dated 12/04/95.

	   This explains the rabid vituperation that can be found in
	   Dr. Fremed's purported reviews of my medical records, and
	   also why he fails to mention having read the named complaint
	   to the New Jersey DOI.

	   On these grounds alone, Dr. Fremed's opinions should be
	   dismissed by any Court as a maliciously perpetrated vendetta,
	   as well as a deliberate sham presented to an adjudicating
	   body of the State of New Jersey together with SFI, and
	   its attorneys in, at very least malicious misrepresentation.

       10) Whether of not Dr. Fremed actually had in his possession,
	   documents which he claims he did not, or whether he had
	   access to documents that are not mentioned, it is clear
	   that the axe Dr. Fremed had to grind was of an imperative

	   From other documents that Plaintiffs have, it is
	   clear that Dr. Fremed, SFI, and Melli, SFI's attorneys,
	   as participants in a racketeering enterprise, were in a
	   well defined conspiracy to commit fraud, robbery and extortion,
	   as well as other criminal acts, intentional and negligent torts.

	   It is also clear that these same participants have committed
	   fraud and extortion as well as other intentional and other
	   negligent torts.

	     Works Consulted in Writing this Memorandum Analysis

		1. Gray's Anatomy, Henry Gay, F.R.S., edited by
		   T. Pickering Pick, F.R.C.S., Robert Howden, M.A.,
		   M.B., C.M. (1901)

		2. Review of Gross Anatomy, Ben Pansky, Ph.D., M.D.
		   and Earl Lawrence House, Ph.D. (3rd ed.) Macmillan

		3. Atlas of Clinical Anatomy, Richard S. Snell, M.D.,
		   Ph.D., Little, Brown & Company (1978)

		4. Correlative Neuroanatomy and Functional Neurology,
		   Joseph G. Chusid and Joseph, J. McDonald (8th ed.)
		   Lange Medical Publications (1956)

		5. Introduction to Physiological Psychology, Francis
		   Leukel, C.V, Mosby Company (1968)

		6. An Introduction to Molecular Neurobiology, Zach
		   H. Wall (ed.), Sinauer Associates (1992)

		7. Ionic Channels of Excitable Membranes (2d ed.)
		   Bertil Hille, Sinauer Associates (1992)

	Respectfully Submitted:

        William C. Hammel                     Alan J. Bellamente
        A-11 Moose Branch Road,               A-11 Moose Branch Road,
	Sweetwater Apartments 1A,             Sweetwater Apartments 8A,
        Robbinsville, NC 28771                Robbinsville, NC 28771
        (828) 479-1547                        (828) 479-1547

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

        DATE: February 4, 2000                DATE: February 4, 2000

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Created: February 4, 2000
Last Updated: May 28, 2000