The Horror of State Farm Insurance

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The Inescapable Result of the Corruption of the State Government of New Jersey and the Racketeering of State Farm Insurance, and the Necessary Fight for Survival, a RICO suit in US Federal Court:
Hammel, et al. v. State Farm, et al.

[IME Medical Whores] [Fascism and the Art of Medicine]
[Email me: Bill Hammel]

The following is the text of a complaint and the damages done to date of complaint that I sent to the New Jersey Department of Insurance, against State Farm Indemnity and it's spawn.

It goes almost without saying that absolutely no investigation was done by the New Jersey Department of Insurance. They merely asked the Insurance Company what it had to say. Its people lied through their teeth and that was the end of it. Subsequent intervention by State Senator Byron Baer and by State Assemblywoman Loretta Weinberg had no results, not for lack of trying.

State Farm Indemnity of New Jersey has deliberately and maliciously committed fraud and the government of the State of New Jersey in the persons of Governor Christie Todd Whitman and her pomps have knowingly and deliberately aided and abetted it, if not ordered it to begin with.

The entire State Government of The State of New Jersey is engaged along with State Farm Insurance and I amd sure other insurance companies in Fraud, Extortion, Racketeering and systematically attempted murder.

Also see the following:
  1. Ingalls v Paul Revere in the matter of Bad Faith
  2. Judy Morris v UNUM
  3. More Insurance News
  4. Life Insurer Fraud
  5. State Farm wants to run Banks TOO?!!
  6. The Mythology of Insurance
  7. State Farm Adjusters
  8. State Farm in the News
  9. A Converstation with a State Farm Claims Agent

December 4, 1995

                     COMPLAINTS AGAINST

                  State Farm Insurance Companies:
                  State Farm Indemnity Company,
                  40 West Century Road
                  Paramus NJ 07652
                  Jane Savastano, Sandra Romei, Veronica Wade,
                  Idiana Murray, individually and as agents,
                  servants and/or employees of
                  State Farm Insurance Company.

                  Dr. William C. Hammel
                  219 Teaneck Road
                  Ridgefield Park NJ 07660
                  (201) 807-0652

          On behalf of Myself

          Dear Sirs:

               Whenever "State Farm" is  used  it  will  mean  "State  Farm
          Insurance  Companies: State Farm Indemnity Company, their agents,
          servants and/or employees."

               On September 16, 1994, Mr. Bellamente and I were covered  by
          State  Farm  policy, number X14107-A12-30 covering a 1992 Mercury
          Grand Marquis, bearing New Jersey registration plates WH AB.   We
          had  elected  the  highest  priced  P.I.P. coverage possible; our
          policy  was  paid  up  to  date.   On  September  16,  1994,  Mr.
          Bellamente  and  I  were both injured in an accident while in the
          aforementioned vehicle.  As we were turning into our driveway  we
          were  struck  in  the  rear.  All appropriate filings and reports
          were made in a timely way.  Although we were both injured in this
          accident,  here,  it  is  my  own  injuries  and  subsequent  ill
          treatment and the lack of treatment about which I complain.

               At the time of the accident of September  16,  1994,  I  was
          sufficiently  concerned  with  Mr.  Bellamente's  disorientation,
          nausea, and pain, that I immediately called the  Ridgefield  Park
          Police,  and  Mr.  Bellamente was taken by ambulance to Holy Name
          Hospital with nausea, disorientation and severe pain in his  neck
          and  back.  I followed the ambulance to the hospital and remained
          while he was treated.  When he was released I drove him home.  It
          was only later when he was resting that it became apparent that I
          also was not as well off as I thought.   During  the  night,  the
          pains  of  neck, back and right shoulder became quite intense and
          sleep disturbing.  On waking in the morning, I could scarcely get
          out of bed, and saw My chiropractor Dr. Peter N. Boulukos.

               Since it has been my custom for a good many  years  to  keep
          myself  in  shape  through  regular  cardiovascular  workouts and
          weight training, it was also my custom as it is with  many  other
          weight training people, to have periodic tune up adjustments by a
          good chiropractor.  I managed  to  get  to  my  chiropractor  Dr.
          Boulukos' office that very day, September 17, 1995, at which time
          he took a complete spinal x-ray  series.   These  demonstrated  a
          reversal of curvature in the neck, and a rather disturbing series
          of  subluxations  that  made  the  lumbar  spine  look   like   a
          step-ladder.   Neither one of these configurations was present in
          the preliminary spinal x-rays that Dr. Boulukos  takes  with  any
          new  patient,  when I first saw him back in the '80s.  I have not
          been in  any  automobile  accident  or  had  any  other  kind  of
          traumatic injury in well over 30 years.  My blood pressure at the
          time before the accident was consistently  in  the  120/80  range
          with the low pulse rate of someone who exercises regularly.

               Chiropractic   care   seemed   the   most   reasonable   and
          conservative course of treatment at the time.  I saw Dr. Boulukos
          three to four times a week, and although the progressive recovery
          was slow and with fluctuations, it was real.  The slowness of the
          recovery was undoubtedly due to the fact  that  my  partner,  Mr.
          Bellamente,  and  I both ran a new retail business, a video store
          and were both damaged in the  aforementioned  accident.   Staying
          home,  staying  in  bed  were  not  options.   Wearing  a wide 6"
          weightlifting belt cinched very tightly allowed  me  walk  almost
          like  a  human  being,  and  therefore to walk to and stay at the
          store for a  few  hours  at  a  time.   The  pain,  however,  was
          completely  continuous.   I  also  had  a  computer  software and
          consulting business.  Once again, "calling in sick"  was  not  an
          option.  Ultimately I had to abandon the computer work, while Mr.
          Bellamente and I struggled to maintain the video business.

               On February 15, 1995, I was examined, in accordance with  an
          IME demand by State Farm, by Dr. James F. Linder.  His report was
          received by State Farm according to their stamp, on February  21,
          1995.   I  received a letter, dated April 28, 1995, 71 days after
          the examination, and signed by Jane Savastano  claims  specialist
          for  State  Farm,  which  referenced  and  enclosed a copy of Dr.
          Linder's report, which is in my possession and the possession  of
          my attorney.  The letter from State Farm also states:

               "We will be requesting  another  independent  exam  shortly,
               regarding your treatment."

               I quote Dr. Linder's  diagnoses  contained  In  his  report,
          dated February 16, 1995:

               1) Cervical Whiplash Injury with
                  Chronic Cervical Sprain/Strain

               2) Myofascial Pain Syndrome - Cervical

               3) Muscle Tension Headaches secondary to #2

               4) Lumbar Sprain/Strain

               5) Myofascial Pain Syndrome - Lumbar

               6) Lumbar Instability

               In his report, Dr. Linder States further:

               "The opinions expressed in this report are  based  upon  the
               history  of  the  injury  as  presented  by the patient, the
               patient's medical history and  examination  findings  and  a
               review of the x-rays presented by the patient.

               "Mr Hammel is currently  experiencing  the  residuals  of  a
               posttraumatic injury to the neck and back which are causally
               related to the motor  vehicle  accident  which  occurred  on
               9/16/94.   It  is  my  professional  opinion that Mr. Hammel
               would benefit from an  additional  8  weeks  of  care  at  a
               frequency  of  2/week  at  which  time the patient should be
               re-evaluated.  In addition to chiropractic manipulation  and
               appropriate  physical therapy modalities when necessary, his
               treatment program should include  stretching  exercises  for
               the  involved  cervical  and  lumbar musculature, along with
               cervical and lumbar stabilization exercises."

               On May 3, 1995, I was once  again  examined,  in  accordance
          with  an  IME  demand by State Farm, by Dr. James F. Linder.  His
          report was received by State Farm according to their stamp on May
          17,  1995.   I received a letter dated July 27, 1995, enclosing a
          copy of Dr. Linder's second report dated May 3, 1995, which is in
          my  possession  and  the  possession of our attorney.  The second
          paragraph of this letter from State Farm signed by Jane Savastano
          states in its entirety:

               "In the doctor's opinion, no further treatment is  necessary
               as a result of your September 16, 1994 accident.  We will be
               unable to consider any further expenses after July 26, 1995.
               If  there  are  any unpaid bills, please send them to me for
               consideration of payment."

          IMPLIED IN DR. LINDER'S REPORT!  The letter written and signed by
          Jane Savastano, which I have in my possession and which is in the
          possession of our attorney, was a lie.

               In  fact,  the  section  of  his  report  entitled,  PRESENT
          DIAGNOSTIC IMPRESSION (May 3, 1995), reads in its entirety:

               1) Cervical Whiplash Injury
                  Chronic Cervical Sprain/Strain

               2) Cervical Spondylosis with Central Canal and Right
                  Lateral Recess Stenosis C4-C5, C5-C6, and C6-C7

               3) Myofascial Pain Syndrome - Cervical

               4) Chronic Low Back Pain Secondary to Ligamentous
                  Instability and aggravated by the Motor Vehicle

               5) Lumbar Spondylosis with Posterior Disc Bulging and Likely
                  small Disc Herniation at L5-S1 and Diffuse Disc Bulge at
                  L2-L3 through L4-L5 with Borderline Central Canal Stenosis
                  at L2-L3.

               6) Myofascial Pain Syndrome - Lumbar

               7) Right A/C Degenerative Changes - Rule out Impingement Syndrome

               Furthermore Dr. Linder's following and  terminal  DISCUSSION
          section,  in which he states his true opinions, I will also quote
          in its entirety:

               "The opinions expressed in this report are  based  upon  the
               history  of  the  injury  as  presented  by the patient, the
               patient's medical history and  examination  findings  and  a
               review of the radiographs presented by the patient.

               Mr.  Hammel  has  indicated  that  there  continues  to   be
               improvement with an overall decrease in the scope, intensity
               and frequency of his and back pain, but that there has  been
               an  increase  in  the  pain in the right shoulder.  It is my
               opinion that Mr.  Hammel  would  continue  to  benefit  from
               additional care at a frequency of no more than 2 time a week
               for 6 weeks and once a week for 6 weeks.   The  patient  has
               indicated that he has been placed on a very limited exercise
               program consisting of some lumbar stretching exercises.  The
               exercise program should be expanded to include stabilization
               exercises for both the lumbar and cervical spine regions.

               "In addition, I  would  reccommend  [sic]  that  Mr.  Hammel
               undergo  an orthopedic evaluation to rule out an impingement
               syndrome and to assess whether this condition is related  to
               the  motor vehicle accident in question or whether there was
               pre-existing  pathology  which  is   contributing   to   the

               Before the first examination by Dr. Linder, I had not known,
          nor known of Dr. Linder, nor met, nor ever seen him.

               I emphasize that I had, and continued to have no problems or
          disagreements  with Dr. Linder personally, nor with either of his
          thoroughly professional examinations,  nor  with  either  of  his
          thoroughly professional reports.

               I called Jane Savastano at 1:55 PM on Monday July 31,  1995,
          in  order  to  discuss the contradiction in her letter dated July
          27, 1995 of Dr. Linder's May 3rd report.  She was, of course, not
          available, and I received no callback.  I called again at 2:30 PM
          the same day and received no callback.  I called again  somewhere
          before  3:40  PM,  making  it perfectly clear that I was going to
          make an extreme pest of myself until I spoke with her.  She spoke
          with  me,  and I explained the ridiculousness of the letter.  She
          said not to worry that it was just a formality  and  didn't  mean
          anything.   This  was  also  clearly  a lie, since NOTHING, to my
          knowledge, has been paid by State Farm since.

               Dr. Boulukos, Dr. Kluger, Dr. Schmaus, Dr.  Sender  and  Dr.
          Savatsky,  out  of  kindness and professional concern, have still
          given me medical attention despite State Farm's  intentional  and
          premeditated delinquency and dishonesty.

               I seek payment to these people for  their  medical  services
          together with the interest that is due them by law.

               Since the time of the benefit denial letter (July 26  1995),
          I  continue  to  have  incapacitating episodes of severe back and
          neck pain and spasm.  The shoulder inflammation, as it turns  out
          of  the  rotator  cuff, has flared up so severely that it, caused
          many sleepless nights and  took  many  weeks  of  high  doses  of
          anaprox  (sodium  naprocyn)  to  bring it under control.  I still
          have a residual malfunction  of  the  shoulder,  which  has  been
          diagnosed  by  both Dr. Peter H. Schmaus and Dr. Gary Savatsky as
          frozen shoulder syndrome, the result of tendonitis caused by  the
          accident of September 16, 1994, for which they have both given me
          prescriptions, which are in my possession and in  the  possession
          of  our  attorney, for physical therapy.  I have not been able to
          obtain this needed therapy which was also indicated as  necessary
          by  Dr.  Linder,  State  Farm's  own  examiner  as well as by Dr.
          Schmaus and Dr. Savatsky.

               Since  State  Farm  continues  to  deny  me   any   benefits
          whatsoever,  with  not  one  shred  of  evidence of any kind that
          denial is appropriate,  I  still  suffer  with  a  malfunctioning
          shoulder.   I  still suffer from lumber and cervical malfunction,
          which slowly, however, continues to improve, as a consequence  of
          Dr. Boulukos' treatment, for which he has not been paid, by State

               The amount of time, energy, expense and effort that has been
          expended  by  Mr.  Bellamente,  Dr.  Boulukos,  Dr.  Schmaus, and
          myself, in attempting to  induce  State  Farm  to  recognize  and
          rectify its own self-contradiction and to perform its contractual
          duties has been prodigious.  All such attempts have been met with
          lies, evasiveness, avoidance and complete intransigence.

               I have repeatedly  pointed  out  that  Dr.  Linder's  second
          report  contains no reason whatever for denial of benefits, to no
          avail.  I still continue treatments  with  Dr.  Boulukos  because
          they are still necessary.

               Letters and  phone  calls  to  State  Farm  by  me,  by  Mr.
          Bellamente  and  by  Dr.  Boulukos  have  produced  no  response.
          Letters sent  to  State  Farm  have  consistently  been  lost  or
          misplaced,  or "not received", or simply ignored.  Phone calls to
          "Claims Specialists" produce no return calls.  A claim  file,  or
          so  I  am told by the Claims Specialists, and/or there assistants
          and/or secretaries, apparently requires days going into weeks, to
          find  or retrieve.  My credulity fails on this point.  The person
          whose name is on any correspondence is always, on  another  line,
          not at her desk, not available, at a meeting, not in for the day,
          or has just left.  Repeated attempts at contact  simply  resulted
          in surly and/or downright rude responses from various secretaries
          and/or assistants.

               State Farm has either been totally silent or  simply  issued
          edicts  and  commands  consistent  with  the  high commands of an
          irresponsible  fascist  bureaucracy.   and  has  been   otherwise
          consistently inaccessible and evasive with any attempt to counter
          their assertions and denial of benefits.

               It is clear at this point that this  intransigence  must  be
          dealt with through some other channel.

               It is clear that I am not dealing  with  some  oversight  or
          some  excusable failure to act in a timely way.  With State Farm,
          I am dealing with,  at  very  least,  negligent  and  intentional
          fraud, to deny me the P.I.P. benefits that we have paid for.

               It is also  clear  that  this  fraud  is  conspiratorial  in
          nature, and most probably rampant.  Further indication of this is
          the following:

               Apparently, finally realizing that they had no  grounds  for
          their  arbitrary  decision  to  deny  benefits,  they  decided to
          provide some.  In a letter from State  Farm  dated  September  21
          1995,  and  signed  by Idiana Murray, another "Claim Specialist",
          another demand  was  made  for  an  other  allegedly  independent
          medical  examination,  this  time  with  one Dr. Harry Merliss of
          Hackensack.  I decided to make extensive investigation that would
          be  statistically  significant  (I am a mathematician among other
          things) of the qualifications and reputation of Dr. Merliss among
          medical   professionals.    It   seems   that   every  healthcare
          professional  I  spoke  with  had  heard  of  Dr.  Merliss.   The
          comments,  all  beginning with a chuckle, ranged from "a favorite
          of the insurance companies", through various horror  stories,  to
          "old  Harry would say you were fine if you had no heartbeat", and
          "even judges laugh at that one".  All  responses  concerning  Dr.
          Merliss   were   of   the   same  kind,  with  not  one  response
          contradicting the  uniform  consensus.   On  the  basis  of  this
          consensus, I believe that State Farm, its agents, servants and/or
          employees knew, or certainly should have known  of  Dr.  Merliss'
          reputation;  and  I  further  believe  that  he  was  selected as
          examiner precisely for his reputation, and  that  his  reputation
          was  based  on  his  actions  in the past.  The obvious intent of
          State Farm, its agents, servants  and/or  employees  is  then  to
          obtain  a  medical  opinion upon which a continued fraud might be
          based and continued.

               Upon receipt of Idiana Murray's letter, I immediately called
          and  wrote  State  Farm  and  told  them  that  Dr.  Merliss  was
          unacceptable   as   an   examiner.    (I   maintain   phone   log
          documentation.)  When  I called Idiana Murray on this matter, she
          was, of course, very busy,  and  I  elected  to  speak  with  her
          assistant.  I was told by her rather insolent assistant that, "We
          decide who is acceptable." My response was, "That may be  but  it
          is  our legal right to refuse this particular examiner." To which
          she responded, "I'm not here to argue with you."  Then  she  hung
          up.   This  was  on  October  18,  1995.   But for another failed
          attempt at telephonic communication on October 20, 1995 that  was
          my last phone contact with anyone at State Farm.  To date we have
          not been contacted in any way by State Farm regarding any  future
          examinations.   Of  course,  no  bills  have been paid, including
          those from before the date of denial.  Payments  for  medications
          have  had  to  come out of our own rapidly diminishing resources,
          the continuing diminishment being caused by arbitrary  denial  of
          benefits and malicious fraud by State Farm.

               Mr. Bellamente and I both work at the same business, a video
          store  which  has  now,  as  a  consequence of State Farm's fraud
          become our only source of income, and  due  to  the  rather  sick
          games  being played by State Farm Insurance, its agents, servants
          and/or employees.  We must  both  work  somehow  or  starve,  and
          decide  on  the basis of who hurts the least at any given moment.
          Even further, to deal almost every day with the  consequences  of
          this  fraud, has caused us on numerous days to abandon the store,
          for an entire day or part of a day  for  medical,  psychological,
          and  legal help as well as having to take the time and expend the
          energy to prepare and assemble documents such at this.

               This drain on our combined time and energy, at a  time  when
          it  can  be least afforded, continues, to this moment, to destroy
          our now only, and insufficient, source of income.  The  financial
          damages  caused  by  malicious  fraud  of State Farm, continue to
          accumulate.  The multitudinous damages, psychological, emotional,
          physical,  and  financial  all worsening as a consequence of this
          fraud have become intolerable.

               The additional  drain  necessitated  by  having  to  respond
          continuously  to the damages and the fraud, as well as the stress
          level caused by not being able or even, permitted by State  Farm,
          to address it all has become intolerable.

               Additionally,   I   now   suffer   psychological   problems,
          completely  new  to  me,  as  a  direct result of the harassment,
          fraud, larceny and their deliberate actions  the  perpetuate  and
          aggravate    the   already   existing   physical   damage.    The
          psychological problems caused by State Farm have  further  caused
          more  life  threatening  physical  problems, which I elaborate on
          below and further caused enough financial problems to  result  in
          imminent  financial  destruction.   I  am  currently, and for the
          first time in my life,  under  the  care  of  a  psychotherapist,
          having  to  take  anxiolytics  and antidepressants to maintain my

               Neither Mr. Bellamente nor I am able to  maintain  order  in
          business,  home,  what remains of personal life and mind.  Though
          we are friends of long standing, we are scarcely able  to  be  of
          assistance to each other.  We do not and cannot manage to cook or
          clean, because of the drain on us  and  damage  done  to  us.   A
          nutritionist  would  gasp  at  our  supposed diet, which consists
          almost totally  of  deli'  food,  sandwiches  and  various  fatty
          salads.   A  consequence  once  again  of having neither time nor
          energy to do otherwise, and the board of  health  would  probably
          condemn  our  quarters.   My  customary exercise program has been
          made impossible by State Farm's harassment, negligence and fraud.
          If  the  necessary  and  appropriate  medical care were provided,
          according to contract, by State Farm, instead of  the  harassment
          and  fraud  that  was,  in fact, perpetrated, and continues to be
          perpetrated, the numerous damages and destruction that  has  been
          wrought would not have occurred.

               Being quite aware  of  my  overall  damaged  and  precarious
          condition  caused  by  the accident of September 16, 1995 and the
          various synergistic damages caused by the fraudulent behavior  of
          State  Farm,  its  agents,  servants  and/or  employees I made an
          appointment to  see  my  internist.   On  that  appointed  visit,
          November  6,  1995 to Paul S. Sender, M.D., my internist of about
          12 years, who prescribes for me, his standard taking of my  blood
          pressure   showed   a  blood  pressure  of  160/80  and  a  pulse
          significantly more rapid than usual.  He has monitored  my  blood
          pressure  and  pulse  over  these  12 years and knows that is not
          normal for me.  He was sufficiently concerned  about  my  current
          psychophysical  state  that  he  ordered a blood workup which was
          performed at 1:00 PM November 13, 1995 by Corning Metpath and  an
          EKG,  that  was  performed  immediately.   In  view of my general
          precarious state caused by State Farm, I was also given influenza
          vaccine.   In agreement with with my psychotherapist, Dr. Kluger,
          Dr.   Sender   immediately   prescribed   an    anxiolytic    and
          antidepressant,  copies  of which are in my possession and in the
          possession of our attorney.

               The EKG unfortunately showed a change from my usual baseline
          EKG that indicating a diagnosis of a silent heart attack.

               The Blood work report which I have in my possession  and  is
          in  the possession of our attorney, showed serum lipid values all
          dangerously above the established reference ranges.  The  overall
          conclusion  of the blood report signed by: Raymond Gambino, M.D.,
          Joseph E. O'Brien, M.D., Paul A. Krieger, M.D.  Kim Lamon,  M.D.,
          and Sherif Nasr, M.D. concludes:


               Dr. Sender has also  prescribed  medications  to  lower  the
          serum lipid score, particularly the very high cholesterol level.

               I was, of course, horrified, but not completely surprised by
          these  revelations.   If  State Farm, its agents, servants and/or
          employees can keep up their good work, then perhaps they will not
          have  to  pay anything, since certainly, they will surely attempt
          to claim, my death by cardiac arrest cannot be accident related.

               Psychotherapy and psychotropics notwithstanding, I have  now
          become devoid of all patience with this perfectly calculated evil
          and will very  soon  become  devoid  of  all  civility  if  these
          murderous  and thieving troglodytes are not stopped and subjected
          to the most appropriately severe punishment.

               I am, therefore, accusing State  Farm  Insurance  Companies:
          State  Farm  Indemnity,  their agents, servants and/or employees,

          1)   Intentional, premeditated and calculated Fraud;

          2)   Intentional, premeditated and calculated Breech of contract;

          3)   Reckless endangerment of my life and limb;

          4)   Premeditated and  intentional  calculated  damage  including
               that of possible death;

          5)   Intentional,  premeditated  and  negligent   infliction   of
               irreparable physical damage;

          6)   Intentional, premeditated and negligent infliction,  over  a
               long   period   of  time,  of  severe  mental  distress  and
               harassment, to an extent  that  requires  my  treatment  and
               medication by a physician, a psychotherapist; and

          7)   Intentional,  premeditated  and  negligent   infliction   of
               annihilating financial damage; as well as

          8)   Violations of the Fair Claims Act.

___________________________________     ___________________________________

    Dr. William C. Hammel                         Notary Public

                        IT AGENTS, SERVANTS AND/OR EMPLOYEES.

               Whenever "State Farm" is  used  it  will  mean  "State  Farm
          Insurance  Companies: State Farm Indemnity Company, their agents,
          servants and/or employees."

               I suffer continued impairment  of  R.  Shoulder,  20  to  30
          degrees  loss of ranges of motion, for which physical therapy has
          been prescribed by both Dr. Schmaus and Dr. Savatsky, and  denied
          by State Farm.

               I suffer persisting damage to rotator cuff of  R.  shoulder,
          where  use  causes severe and painful tenosynovitis that can only
          be   treated   with   high   doses   of    prescribed    powerful
          anti-inflammatories  whose  long  term  use  is  known  to  cause
          gastrointestinal, liver and kidney damage.

               I suffer maliciously intentional and negligent infliction by
          State  Farm  and  specifically  by  their agents, servants and/or
          employees Jane Savastano, and Idiana Murray, of mental  distress,
          insomnia,  depression and anxiety so as to require treatment by a
          psychologist and a physician.  The  emotional  and  psychological
          damages  are severe enough to demand prescribed medication in the
          form antidepressants and anxiolytics the  long  term  effects  of
          which are unknown.

               I hold State Farm wholly responsible  for  residuals  and/or
          sequelae  from  the use of the potent medications that I have had
          to be given because of its fraud and the consequences thereof.

               The source of  these  emotional  and  psychological  damages
          being   unwarranted  denial  of  benefits,  their  avoidance  and
          evasiveness with regard to my legitimate  claims,  the  arrogance
          and  surliness  of  their  assistants  and/or  secretaries, their
          mendaciousness, and total lack of response to logic and empirical
          evidence of any nature.

               A  further  source  of  these  emotional  and  psychological
          damages  being  a  protraction  of  recovery  period for physical
          damages  sustained  in  the  accident  of  September  16,   1994,
          inability  to  work  and therefore loss of income from my work as
          systems analyst, computer programmer and consultant.

               A  further  source  of  these  emotional  and  psychological
          damages  being  that I work in pain an restriction in work at the
          one source of insufficient income  that  I  have  left,  a  video
          business, which I will have to sell at a loss.

               A  further  source  of  these  emotional  and  psychological
          damages  being  that  I work and live with Mr. Alan J. Bellamente
          who was also severely injured in the accident  of  September  16,
          1994,  and who has become as unable to maintain house and life as
          I, and who has also been unwarrantedly denied benefits  by  State
          Farm,  and  the  two  people  named above.  I see him deteriorate
          mentally and physically more every day.  I have filed a complaint
          on his behalf because he is presently not able to do so himself.

               I suffer the physical damage of a  significant  rise  in  my
          normal  blood  pressure  from  120/80 to 140/80, and a cardiogram
          that my internist Dr. Paul Sender diagnosis as the result  of  an
          occurrence  of  a  silent  heart  attack, for which I blame State
          Farm.  My previous cardiograms showed no such anomalies.

               I suffer financial damage  from  my  inability  to  maintain
          physically  and  mentally  my  business as computer consultant at
          all, resulting in complete loss of income from that source.

               I suffer financial damage from  my  inability  to  maintain,
          physically  and  mentally, my retail business, and the consequent
          necessity of selling it quickly and at a considerable loss.

               I suffer financial and personal damage from my inability  to
          maintain  my  place  of residence in the State of New Jersey, and
          emotionally, from my dependence on a friend to provide me with  a
          place to live.

               I  demand  immediate  reinstatement  of   P.I.P.   benefits,
          according to contract and the Fair Claims Act.

               I demand compensation, beyond and excluding P.I.P. benefits,
          for  all damages already caused by the unwarranted and fraudulent
          actions State Farm, and all consequences thereof, past,  present,
          and future, and that State Farm cease any and all perpetration of
          further fraud and damage immediately.


                  Damages Incurred by any malfeasances
                  or civil actions due to my state of
                  mind caused by mental, physical,
                  emotional and financial abuses of
                  State Farm                              $ (unknown)
                  Loss of Income from Retail business     $  7000.00
                  Loss of Business and Good Will, and
                  therefore the value of the business
                  caused by closing of business in
                  order to address the fraudulence of
                  State Farm                              $ 20000.00
                  Capital Loss from Sale of Retail
                  Business                                $ 70000.00
                  Loss of Earnings as Computer
                  Consultant, Analyst and Programmer      $ 15000.00
                  Loss of Equity in Partially Restored
                  Antique Mercedes Benz from forced
                  liquidation                             $ 11000.00
                  Cost of Relocation                      $  5000.00
                  Professional Services incurred by the
                  fraudulence of State Farm               $  2500.00

                  Subtotal:                               $130500.00

               I further  demand  that  all  future  "Independent"  Medical
          Examinations  be mutually agreed upon, *truly* independent, and
          not fraudulent farces.

                           AND TO THE FRAUD OF STATE FARM:

                  Prescribed Medications:                $   290.55

                  Subtotal:                              $   290.55

                                UNPAID MEDICAL BILLS:

                  Teaneck Radiology                       $   902.00
                  Dr. Peter N. Boulukos                   $  2565.00
                  Dr. Peter H. Schmaus                    $   321.00
                  Dr. Gary Savatsky                       $   150.00*

                  Dr. Albert Stabile                      $   180.00
                  Dr. Paul S. Sender                      $   250.00*
                  Dr. Martin A. Kluger                    $   680.00*
                  Subtotal:                               $  4048.00

                  Subtotal:                               $  4338.55

                  TOTAL:                                  $135129.10 +

          * Not immediately available, and estimated

               I am  demanding  that  these  bills  be  paid  according  to
          contract together with the interest that is due according to law.

               I further demand compensation for the damages done me by the
          intentional,  negligent  and malicious fraud perpetrated by State

___________________________________     ___________________________________

    Dr. William C. Hammel                         Notary Public

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Created: 1997
Last Updated: May 28, 2000