First Amendment Violation Disguised as a Protective Order

My Reply to a Perpetrator Guardian ad Litem’s Attempt to ‘Reverse Victim and Offender’

People sometimes ask me: if such horrific violence is happening in the Family Courts against children and the adults trying to protect them, wouldn’t the world know about it by now? Actually, no. When it comes to atrocities, the more they exceed the imagination, the less they come into consciousness. And the more violent the perpetrators, the more aggressively they will crush dissidents, silence whistleblowers, and persecute truthtellers behind the scenes. Consider how far the Nazi Holocaust advanced before the German population knew about it; even after their cities were bombed into ashes, they refused to believe, until the Allied Forces physically took them to the death camps to see. When mass oppression is happening, stifling reporting and shaping the narrative is all it is about: child abuse is good parenting, protecting children is a criminal offense, etc. This is why a certain “guardian ad litem” (“GAL”), after failing to impede my First Amendment rights by every other method, had a crony Family Court judge issue a “protective order” against me, even though truthful public reporting is not “harassment”, and appearing at a public meeting by invitation is not “stalking”. Below is my response:

I, BANDY LEE, of full age, do hereby Certify/Swear as follows:

1. As usual, [GAL] is looking only for legal loopholes in order to obfuscate and to try to circumvent the most critical, fundamental fact: that she committed fraud to deprive a rightful parent of her children and to damage and destroy them for life. In the process of her doing so, she needed to silence witnesses such as myself, and therefore assailed, entrapped, and falsely arrested me and other innocent persons, such as a renowned expert on child abuse and torture, by intimidating us and tampering with the evidence we brought. Her 350 lies in official proceedings, while pretending that she was telling the truth, and her 250 acts of perjury under oath, should serve as proof of her mendacity, criminality, and fraud.

2. [GAL] cannot respond to even a single one of my accusations, because she has nothing to say. All my statements are truthful.

3. Plaintiff also cannot cite a single act of harassment, as defined by N.J. Rev. Stat. § 2C:33–4 (2023):

[making, or causing] to be made, one or more communications anonymously or at extremely inconvenient hours, or in offensively coarse language, or any other manner likely to cause annoyance or alarm; [subjecting her] to striking, kicking, shoving, or other offensive touching, or threatens to do so; or [engaging] in any other course of alarming conduct or of repeatedly committed acts with purpose to alarm or seriously annoy such other person.

4. Similarly, Plaintiff cannot cite a single act of stalking, as defined by N.J. Rev. Stat. § 2C:12–10 (2023):

directly, indirectly, or through third parties, by any action, method, device, or means, following, monitoring, observing, surveilling, threatening, or communicating to or about, a person…; repeatedly committing harassment against a person; or repeatedly conveying, or causing to be conveyed, verbal or written threats or threats conveyed by any other means of communication or threats implied by conduct or a combination thereof.

5. Instead, “harassment” and “stalking” describe accurately Plaintiff’s own actions against myself and Patricia Lee, in co-conspiracy with Patricia Lee’s violently abusive husband, with whom Plaintiff coordinated in almost every way from the start, even though she was supposed to be the children’s guardian ad litem. Her violent police raids, false arrests, and weaponization of the police have all occurred in co-conspiracy with this violently abusive father and husband, as discovery and phone records have revealed. At times, they made daily phone calls to each other, and they coordinated with the school principal, for example, to call him for one hour each the day before and for a half-hour each the day of our arrests, in order to disrupt, sabotage, and prevent our scheduled meeting with the principal. At the time of our arrest, Plaintiff and Alan T. Chan were both at the school — in only one incident of co-conspiracy among countless many.

6. When Plaintiff added her harassment to Patricia Lee’s husband’s, it did not just cause alarm but caused trauma and a new diagnosis of post-traumatic stress disorder (PTSD), after almost causing her demise. Plaintiff may experience as “harassment” any objection to her near-deadly assaults, her abduction of children, and her extreme deprivation of these children by not allowing a single phone call or even one minute of visitation with the mother who raised them, for three years without due process or cause — and her calling this a “temporary transfer of custody” would be laughable is not so permanently destructive! And truthful reports of her heinous, outrageous, and disgraceful actions may feel like harassment to her, but this is not the definition of harassment. Additionally, appearing at a public Board meeting once, on invitation of members and officials of her community, can under no stretch of the imagination count as “stalking” — especially for Patricia Lee whom I, coming in from New York City, had to solicit for a ride (not to mention that Patricia Lee was invited, too). Plaintiff is accustomed to using gangster-like methods of assault against innocent people with such overwhelming force, that they are rendered incapable of fighting back. Unfortunately for her, I have twenty-five years of experience evaluating and recommending sentences for violent offenders in maximum-security prisons, and I immediately recognized Plaintiff as one of the most extreme and most predatory aggressors I have encountered. Her very insinuation and the “framing” of her victims with her own guilt are the very criminal manipulations I witness every day, and so doing through abuse of authority under color of law is the reason for which she is being federally sued.

7. Similarly, Plaintiff’s and Patricia Lee’s husband’s, Alan T. Chan’s, stalking of me is a well-documented fact, on multiple court records spanning over years. In order to prevent the entry of my testimony onto the divorce court record, as the primary witness against the abusive father’s daily violence against his spouse and children for fifteen months, these two have surveilled, stalked, monitored, character-assassinated, threatened, arrested, and intimidated me as a witness for the last three-and-a-half years. Indeed, their obsession over me predates by at least a year any article I have written, although since I started writing true accounts of their actions, they have become almost hysterical: plastering their motions with my name in every unrelated context (the response to Patricia Lee’s appeal against [GAL], for example, had very little on the actual appellant), bringing me into the divorce case as if I were a litigant myself (even as they denied me my testimony), attempting to pressure and control me through weaponization of the state and local police, and even contacting the journals and magazines that published my interviews — only to be rebuked by their legal departments for violating the U.S. Constitution. This context must be considered if one is to understand her true motives behind this false guise of a “protective order”: to intimidate, stalk, harass, and control me further as a witness, in order to cover up their true, violent crimes. The very fact that she sent Patricia Lee to the emergency room, where the emergency physician ruled her out for a heart attack and a stroke and told her that she almost died (see Exhibit A) — which would not be the first time (see Exhibit B) — should be an objective measure of how violent and dangerous Plaintiff is.

8. That Plaintiff is not the audience of my articles should be obvious from the public’s response to them: several of my articles have had thousands of readers and top many articles I have written on other subjects, showing the resonance I am having with my readers. Also, I had a twenty-two-year career in violence prevention before I ever met Plaintiff and started writing about her shocking, ruthless, unchecked violence. In fact, more than two dozen former and current litigants whose lives Plaintiff has similarly destroyed, by violently abducting their children and transferring them to their rapists, batterers, and attempted murderers, have reached out to me, and this was the impetus of my writing as a form of mandated reporting, since all other avenues of reporting failed (the Office of Attorney Ethics, for example, refused to investigate her). Even those who did not have Plaintiff as guardian ad litem or as children’s lawyer reached out to inform me of other ways she defrauded them: she stole, for example, the equities of at least two entire homes, after having done almost no work. One of them has asked me to perform a psychopathy checklist on her, which is an extensively researched and extremely reliable diagnostic assessment tool (developed in the 1990’s by Dr. Robert Hare) that is based primarily on objective documents and victim interviews. The preliminary results, based on objective documents, are utterly disturbing.

9. If this case is not dismissed, I would like to ask for an evidentiary hearing where I could marshal witnesses. The problem so far has been the absence of any evidentiary hearing or any resemblance of due process. A smoke-and-mirrors guise of “legality” is insufficient, and in this case has been used to cover up the most egregious violations of local, state, federal, and international law. The matrimonial court’s primary weapon has been a Star Chamber-like secrecy — used not to protect children but to commit atrocities against them with impunity — except when [GAL] wishes to file a frivolous protective order, at which time she is allowed to divulge anything from the “sealed” records at will. The same information for which the innocent mother was threatened with incarceration, without any proof that she divulged, is free-for-all for Plaintiff to disclose, when it comes to aiding her criminal ends. [GAL] and Alan T. Chan can even skip mandated court meetings to coordinate their false arrests of medical experts simply trying to fulfill their legally-mandated duty to report child abuse, as they were permitted to do on June 22, 2022, while Patricia Lee was required to attend court.

10. Plaintiff’s continuous, serial lying is especially of grave concern. The 600 documented lies and acts of perjury are not just a number but an indication of pathological lying, a deeper character pathology, and potential dangerousness. Dangerousness makes a person unfit for duty, and scoring disturbingly high on a psychopathy checklist raises alarms that this person is anywhere near children. Predators of children often take on functions in schools, churches, and Family Courts as “guardians ad litem,” in order to gain access to their victims. [GAL] has not only lied but has had to maintain her lies endlessly, since one always needs a new lie to cover over the first lie. This is why plenary hearings with factual evidence are critically important, and it should be noted that not a single hearing has occurred with relevant facts and witnesses, so that her “smoke and mirrors” pretenses would not be debunked with factual evidence.

11. Plaintiff shows more than several disturbing signs of unfitness — not only because of what she has done to Patricia Lee’s children, against the advice of a dozen medical professionals, but what other parents have reported to me. Her pattern is consistent: abducting children from fit, nurturing primary caregivers; imprisoning children with their abusers; and telling the children that their loving parent “abandoned” them and “no longer loves” them. These actions have been committed ruthlessly, repeatedly, and systematically in too many cases to assert that all these cases are so exceptional as to require such extraordinary interventions. The more likely explanation is that Plaintiff is mentally unfit and dangerous to continue to serve in her role.

12. Fitness is presumed until there are signs of unfitness, at which time a petition can be made to the Court for an evaluation. As a seasoned forensic psychiatrist and expert witness for the courts, who has performed more than 200 mental competency evaluations, I request that [GAL] be required to undergo an evaluation of mental competence as well as a dangerousness risk assessment. I also ask that this Court refer her to Criminal Court; Family Courts are ill-equipped to deal with the most dangerous individuals, who are detectable not by the stereotypes common in popular fantasy, but by appearing exceptionally innocent and sympathetic. It was impressive to me just how spectacularly innocent-appearing [GAL’s] public images are,[1] so much so that I created an impression I believed to be more fitting of her true, Machiavellian nature.[2]

13. Like the most violent offenders whom the Law has failed to contain, Plaintiff has tried to cover up her violence with more violence. When her false police raids and false arrests did not work, she assaulted Patricia Lee in ways that almost caused her death, as medically proven multiple times by physicians in multiple documents. When harassing Patricia Lee to deadly levels, beginning in November 2021 and continuing to this day, did not make her “comply” — which for Plaintiff essentially means that a loving mother must obediently watch the medically-proven destruction of her children without legal or constitutional recourse — Plaintiff rained down the most sadistic, heartless, and diabolical acts against these children, such as keeping them totally separated and isolated from the mother who raised them (after which they stopped growing).

14. There are other signs of Plaintiff’s mental unfitness. She negated Alan T. Chan’s diagnosis of psychopathy — confirmed by four forensic medical experts of national and international stature — despite not having any mental health background of her own. She suppressed reports warning of Alan T. Chan’s danger to his children, despite six highly-qualified mental health experts forming a medical consensus — including an expert who is among the most highly-respected in New Jersey Family and Criminal Courts. Plaintiff continued to claim that Patricia Lee was “mentally unfit,” even though ten psychiatric experts disagreed — all of whose reports Plaintiff suppressed. Insistence on reversing sickness and health, in order to deny one’s own sickness, is a common symptom of those who are suffering from mental debility. The inability to accept factual evidence, the need to distort reality to one’s wishful view of the world, and the attacks against anyone who would contradict her beliefs are all signs of mental incompetence.

15. Incapacity to do a job is not incompatible with criminal responsibility. Plaintiff’s frivolous abuses of protective orders, as well as of her legal connections, her authority, and her quasi-judicial immunity as “absolute immunity,” all indicate a criminal mindset. Additionally, Judge Jane Gallina-Mecca’s endorsement means very little, especially when she herself is being referred to the New Jersey Senate for impeachment, after more than 1500 citizen signatories agree that she has committed egregious constitutional violations and human rights abuses (see Exhibits C & D). Plaintiff’s actions consist of some of the worst possible human rights abuses against children, as established by a United Nations Human Rights Council report[3] and a South Texas Family Residential Center study,[4] which no court should condone, no matter the temptation to protect one’s own, after having extensively worked with her in the past.

Subscribed and sworn before a notary public, on October 1, 2024,

Bandy X. Lee, M.D., M.Div.

[1] See, for example, her public profile: [Internet link]. For the trained eye, this level of “total innocence” exuding from a photo is unusual and raises the possibility of predatory manipulation intended to conceal the opposite. At the June 16, 2024, virtual hearing, Plaintiff sat timidly, far in the back, while her attorney defended her from up front. Again, for the trained eye, these are sophisticated theatrics consistent with a highly-skilled predator who uses deception and manipulation to make herself appear “the victim.” Because of these “skills”, the most dangerously-disordered personalities are multifold less likely to be prosecuted and multifold more likely to get out of prison early, despite being more dangerous and more likely to recidivate than those without a dangerous personality disorder.

[2] See my diagram of her “true” personality, in an article that has also garnered considerable public attention (her extraordinary manipulative skills can also be seen in the fact that she managed to remain on a Board despite being voted out — while succeeding in driving out the duly-elected member of the Board!): [My article].

[3] See: https://www.ohchr.org/en/documents/thematic-reports/ahrc5336-custody-violence-against-women-and-violence-against-children

[4] https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0259576