Bandy X. Lee's Blog, page 4

Team Cover-Up: Evelyn Nissirios — Michael Antoniewicz — Jane Gallina-Mecca

Their ‘Job’ is Not Justice, but Covering for Violent Perpetrator and Child Kidnapper, Alan T. Chan

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Triumvirate of Evil: Alan T. Chan — Evelyn Nissirios — Jane Gallina-Mecca

Triumvirate of Evil: Alan T. Chan — Evelyn Nissirios — Jane Gallina-Mecca

They Illustrate How and Why Previously Healthy Young Mothers Simply Drop Dead in Family Court as in No Other Setting

Never have I seen, in my thirty-five years in the medical field, the kinds of unheard-of deaths as occur in Family Court — and then there are the exceedingly rare, debilitating conditions that are ubiquitous in Family Court, for those who survive. It speaks to the kind of heinous human rights abuses that are happening in these so-called “Courts” (in actually, “Anti-Courts” untethered from the Law through self-imposed secrecy and impunity). Conjure up the worst torture and destruction of the human personality one can muster, and it is happening in the Family Courts as routine practice. Here is the rough playbook: kidnap the children from the competent parent (and the more competent the parent, the more violent the kidnap); transfer the children to the child abuser (the more abusive the parent, the more he is likely to traffic them to pedophilic sex rings, which depend on Family Courts for fodder); send the children to brainwashing/torture camps if they resist, or are old enough to become witnesses (this is what “reunification camps” are really about); and decimate the competent parent so that she cannot fight back or be a witness (the first thing Family Courts do is to lock the good parent out of all financial assets and emotional support, issue draconian gag orders, and find some excuse to put her in jail, much like Monica Ciardi, who was almost sentenced to thirty-three years in prison for quoting a judge).

One victim mother recently said to me: “I would have more rights if I murdered my husband and went to criminal court, than if I filed to divorce my husband and went to Family Court.” No description encapsulates the predicament better, in my opinion (of note, while Family Courts are medieval-level patriarchal, what matters even more is who is the abusive parent; if the mother is abusive and the father loving, the children are sent to the mother).

Sudden deaths from heart attacks in young mothers with no cardiac history — the demographic least likely to die from a heart attack — deaths from “broken heart syndrome,” suicides in those with no psychiatric problems, cancer, or stroke tell the story that cannot be spoken in words. My own sister, who was in perfect physical and psychological health, successfully raising two happy, healthy, and thriving children and praised as “the best mom” in her idyllic neighborhood before Family Court, has now suffered nine near-death episodes and is debilitated, requiring round-the-clock care at home since an admission to the intensive care unit, after five years in Family Court. Still, Judge Jane Gallina-Mecca, despite co-conspiring with her violent ex-husband, Alan T. Chan, in multiple attempted murders, insists on presiding over my sister’s temporary restraining order, issued by another judge, in order to cancel it. And both of them are still plotting a police raid of the house in order to finish her off.

A police raid is how my sister lost custody of her two children, when the Court-appointed guardian ad litem, Evelyn Nissirios, lied to the police and perjured 250 times in court to send five police officers to tear the crying and clinging children from their loving mother, on the very weekend she specifically authorized the mother to be with them. This is how, four years ago, she gave these children to Alan T. Chan, a violent, womanizing, substance-abusing, and pornography-addicted psychopath, as duly-diagnosed by four world-renowned forensic experts who warned that he is a danger to his children and unfit to parent — and indeed who was previously on a restraining order, also issued by another judge, for almost killing each of them by head injury.

In my experience, Family Courts more aggressively transfer children to the abusive parent’s sole custody, prohibiting any access to the caring parent or to qualified medical providers, the more serious the abuse is and the more clear-cut the evidence. This is how my sister, who was the sole caregiver of her children since birth, came to lose custody brutally and abruptly, without the ability to see or hear from them for even one minute during the last four years, and cannot even deliver Christmas or birthday gifts via any other relative or friend. What the other victim mother said is correct: she would have more rights to see her children as a mass murderer than as a loving parent in Family Court.

Now, Nissirios is attempting to cause my sister’s demise through an underling judge of Judge Gallina-Mecca (who granted her fraudulent “protective order” against her own victim), while Judge Gallina-Mecca and Alan T. Chan are continuing to attempt to murder her by police raid (Gallina-Mecca’s latest order, for example, is illegal on its face, for it cannot state a reason as is required by law). My sister therefore submitted the following affidavit to the local police:

AFFIDAVIT OF PATRICIA LEE

I, Patricia Lee, swear under oath that Judge Jane Gallina-Mecca’s recent order (see Exhibit A) is legally invalid, unlawful, and unconstitutional and should not be followed. Instead, it is a thinly-disguised attempt to help my ex-husband Alan T. Chan cause my demise. The reasons it should not be followed are below:

First, there is no statement of reason as to why I am in violation, because I am not. “Like an unconstitutional statute, an unconstitutional order cannot be used for enforcement,” one of the most renowned constitutional lawyers in the country, who is working on Judge Gallina-Mecca’s impeachment (see Exhibit B), confirmed.

Second, the Judge is using her orders not to enforce the law, but to break the law in criminally co-conspiring with Alan T. Chan’s to “medically” murder me, as is thoroughly documented in over a dozen medical expert reports. Here are some indisputable facts:

· Alan T. Chan is under a temporary restraining order (TRO) and should not be allowed near the house, let alone be permitted to break in.

· I have a stress-induced, life-threatening medical condition, where an invasion into the house may trigger an immediate stroke or heart attack.

· Eight hospitalizations and one intensive care unit admission in December 2024 (see Exhibit C) confirm the above condition, of which the Judge and Alan T. Chan are fully aware (I was in perfect health before their assaults).

· Judge Gallina-Mecca is currently trying illegally to cancel the TRO, issued by another judge.

· Judge Gallina-Mecca illegally canceled a previous TRO against Alan T. Chan in July 2021, which allowed him to: (a) kidnap the two children he almost killed (and was on the TRO for); (b) orchestrate a police raid against me in an attempt to “medically” murder me; and © imprison the children with him for four years without allowing access to the mother who raised them, which psychiatric experts have called, “soul murder.”

Third, Alan T. Chan’s 17-year history of domestic violence is well-documented, with dozens of police reports made to this Department, and his legal abuse is a part of his Coercive Control, which is now a crime in New Jersey.

Fourth, the last time Alan T. Chan broke into my house against the alarm, under another order by Judge Gallina-Mecca, he did not stay within the parameters he promised to but ransacked the place and committed larceny of my most precious heirlooms and basic necessities (see Exhibit D).

Finally, Alan T. Chan is not entitled to the house. He abandoned it four years ago, and he now owes my sister, Dr. Bandy Lee, more than the equity of the house, for which he is being sued (see Exhibit E).

Judge Jane Gallina-Mecca has been covering up her own, as well as other violent perpetrators’, crimes, through an illegally-issued “court seal.” She has done the same in dozens of other cases, and several murders may be attributable to her (See Exhibits F and G). This is partly why she is being referred for removal from the bench by more than 2000 petitioners and more than three dozen witnesses.

Following illegal orders can also be a crime. In this case, it can be complicity in attempted murder.

Signed and notarized on this 31st day of March, 2025,

Patricia J. Lee

*The police were sympathetic to the above, but Judge Gallina-Mecca and Alan T. Chan have been relentless in their attempt to remove my sister’s temporary restraining order, so as to effectuate the police raid. This caused my sister to have a mini-stroke on April 2, 2025, for which she had to be monitored the whole day, and yet the Gallina-Mecca/Chan duo tried to reschedule their emergency court hearing for the next day, but had to back when they received three doctor’s notes warning that a hearing the next day could kill her. Now, the hearing is scheduled to be held on April 7, 2025. Gallina-Mecca tried to label my sister as “mentally ill” (against eleven psychiatric expert reports unanimously stating that she has “excellent mental health” and “exceptional talent in parenting”) — probably because she herself is unfit and dangerous, which is why there is tremendous momentum to impeach her . Please sign if you have not done so, and help us to reform the dangerously corrupt Family Courts!

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Celebrated Constitutional Lawyer Bruce Fein Helps Challenge the Star Chamber-Like Secrecy of Family…

Celebrated Constitutional Lawyer Bruce Fein Helps Challenge the Star Chamber-Like Secrecy of Family Courts

The First Amendment is a Solution to the Worst Abuses of Authority

Family Courts are so corrupt, even fellow jurists call them “the Sewer.” Secretive like the Star Chamber of seventeenth-century England, where dissidents were persecuted and disappeared, they can easily be weaponized to the same purpose: to retaliate against whistleblowers and dissidents, by taking their children. This happened to former CIA agents exposing the government torture program, and more recently to Jennifer Weisselberg, after she cooperated with authorities looking into the Trump Organization’s finances. Or it can happen to anybody. Family Court keeps each person isolated from the other, because the first most empowering thing for victims is to know what is happening to them — and lots of them!

These “Anti-Courts” exploit the general public trust bestowed on the judiciary to operate a hidden, criminal enterprise that auctions off 100,000 children a year to their torture, battery, rape, sex trafficking, and murder for profits to the tune of 50 to 175 billion dollars a year. A “culture of psychopathy” underlies this child theft operation, which sometimes removes children simply to deprive them of a loving and capable parent. Bruce Fein, Esq., one of the most celebrated constitutional lawyers in the country, who impeached three U.S. presidents, has bravely stepped up to defend my right to expose Family Courts for the centers of organized crime that they are. He will also help guide the impeachment of Chief Family Court Judge Jane Gallina-Mecca, and now even the New York Times has shown interest!

Please read the muckraking article below, bravely written when most witnesses are decimated before they can speak, and journalists lose their lives:

STAR CHAMBER EXPOSED: RENOWNED YALE PSYCHIATRIST SUES TO EXPOSE NJ FAMILY COURTS

Dr. Bandy Lee Slaps NJ Judge and Guardian Ad Litem with Federal Lawsuit over Gag Order and Free Speech Violations

By Richard Luthmann

Mar 25, 2025

Star Chamber Exposed: Yale psychiatrist sues NJ family court over gag order, exposing child abuse cover-ups and judicial corruption.

A top forensic psychiatrist has filed a bombshell federal lawsuit accusing a New Jersey family court judge and guardian ad litem of violating her constitutional rights to silence criticism of court corruption.

Dr. Bandy X. Lee, a former Yale and Harvard professor and renowned violence expert, sued Bergen County Family Court Judge Michael Antoniewicz and guardian ad litem Evelyn Nissirios.

Lee says the duo trampled her free speech rights and weaponized the courts to protect judicial misconduct in her sister’s high-stakes custody battle.

STAR CHAMBER EXPOSED: NOTORIOUS NJ DOMESTIC VIOLENCE

“Family courts are notorious for discounting claims of domestic violence against women and children,” Lee wrote in her lawsuit. “Transparency plays a pivotal role in deterring judicial abuses.”

New Jersey Guardian ad Litem Evelyn Nissirios [dozens of litigants complained to Dr. Lee that she permanently separated them from their children to give them to their abusers, while falsely telling them that their loving parent abandoned them and no longer loved them.]

New Jersey Guardian ad Litem Evelyn Nissirios [dozens of litigants complained to Dr. Lee that she permanently separated them from their children to give them to their abusers, while falsely telling them that their loving parent abandoned them and no longer loved them.]

According to Lee’s 15-page federal complaint, Nissirios sought a bogus Temporary Protective Order (TPO) against Lee on December 5, 2024. Judge Antoniewicz granted the order, forcing Lee to remove all online posts criticizing Nissirios — posts that included explosive allegations of perjury, child endangerment, and collusion with an abusive father, Alan T. Chan.

“The TPO falsely declared, ‘By consent, Bandy Lee shall remove all posts regarding [Evelyn Nissirios],’” Lee wrote.

But Lee never consented — her attorney allegedly did it without authority, and the judge muzzled Lee when she tried to object in court.

“The Court clerk muted her microphone,” Lee’s complaint states.

Lee said she submitted a sworn declaration disputing the so-called consent. Her attorney, Tricia Lindsay, never refuted Lee’s sworn claim. Instead, Judge Antoniewicz “prohibited Plaintiff from reiterating the twin constitutional defenses” that she never consented and that her posts were fully protected by the First Amendment.

Renowned Constitutional Lawyer Bruce Fein [it is extraordinary that an attorney of his stature would offer his help to expose some of the most powerful members of society (judges) profiting off of the most powerless (children).]

“This is prior restraint — the worst First Amendment violation a court can commit,” said Lee’s attorney Bruce Fein. “The Constitution does not stop at the family court’s door.”

At a January 10, 2025 hearing, Antoniewicz held Lee in contempt and fined her $5,381.25 in attorney’s fees payable to Nissirios. Lee was also ordered to stay silent or face jail.

“Dr. Lee has been chilled against writing new posts about Co-Defendant Nissirios in violation of the First Amendment for fear of another court finding of contempt and possible jail time,” the complaint states.

STAR CHAMBER EXPOSED: THE CASE THAT SPARKED THE WAR

Lee became involved after witnessing what she called “heinous abuses” against her sister Patricia Lee in the Bergen County family court. In her censored writings, Lee accused Nissirios and the judge of colluding with Chan, a father with a history of domestic violence.

“GAL has tried multiple times to harm Patricia Lee physically — in addition to raiding her in the most violent fashion possible to rip her crying, screaming, and clinging children away from her,” Lee wrote in a post scrubbed by court order. “GAL is now under criminal charges for her first life-threatening assault.”

Lee blasted the judge’s decisions: “You barred a defendant from choosing her own support for three years — as you systematically isolated, bullied, and tried to break her psychologically.”

She accused the court of ignoring psychiatric evidence that deemed Patricia Lee a fit mother and instead relying on a guardian ad litem who “lied to this Court over three hundred fifty times.”

According to Lee, Chan was initially under a restraining order for seriously injuring the children. But the court handed him full custody anyway, cutting Patricia off from her children for three years.

“Everyone who has seen photos of my sister’s children has commented that they look like they have been interned in a concentration camp,” Lee wrote. “They stopped growing. Both are now the shortest students in their respective classes.”

STAR CHAMBER EXPOSED: A CONSTITUTIONAL SHOWDOWN

Lee’s lawsuit seeks a federal ruling declaring the gag order unconstitutional and wiping out the $5,381.25 fine. She demands nominal damages and attorney’s fees.

Citing New York Times Company v. United States (Pentagon Papers), Lee argues the order is an illegal prior restraint.

She also points to Elrod v. Burns, where the Supreme Court ruled that even temporary free speech suppression causes irreparable harm.

“An unconstitutional court order like an unconstitutional statute cannot serve as the predicate to sanction a violation,” the lawsuit says.

Lee is represented by Fein, a constitutional scholar who served as Associate Deputy Attorney General under President Ronald Reagan, and New Jersey attorney Demetrios Stratis.

EXPOSING THE ‘BIGGEST CHILD TRAFFICKING BUSINESS’

In her censored post, Lee unleashed on the court system: “Family Courts are not real courts — and their whole criminal enterprise would crumble if the world only knew the truth of their atrocities.”

Designer Child Trafficking

She accused family courts of running “the largest child trafficking business in the country,” supplying “pedophilic sex rings and child pornography production.”

“Judges and guardians ad litem ‘fix’ the cases through their own criminal activity, which they conceal under ‘court seals,’” Lee wrote. “The practice has become so lucrative, there are hardly exceptions: almost no victim child goes to the right parent.”

Lee added: “Nearly a thousand children have been murdered through this arrangement, and mothers are dying at alarming rates, just as my sister almost died recently from GAL’s harassment.”

STAR CHAMBER EXPOSED: FIGHTING FOR TRANSPARENCY AND JUSTICE

Lee’s lawsuit highlights a growing national backlash against family court secrecy. The United Nations has documented the global trend of courts dismissing domestic violence and child abuse claims in custody cases.

“The tendency to dismiss the history of domestic violence extends to cases where mothers and/or children themselves have brought forward credible allegations,” the U.N. reported in 2023.

Fein said the case is about more than one family. “This is a battle for the Constitution, for free speech, and against judicial tyranny.”

The case is pending in the U.S. District Court for the District of New Jersey. Lee and Fein vowed to appeal all the way to the U.S. Supreme Court if necessary.

“I refuse to be intimidated,” Lee said. “Sunlight is the best disinfectant. It’s time to expose these courts for what they really are.”

(The original article can be found here: https://luthmann.substack.com/p/star-chamber-exposed-renowned-yale.)

*All legal nonfeasance, malfeasance, and misfeasance connected to this case trace back to Chief Family Court Judge Jane Gallina-Mecca. Evelyn Nissirios is her disciple, and Michael Antoniewicz her subordinate judge. Please join our tremendous momentum to impeach Judge Jane Gallina-Mecca  — which has the potential finally to fix the hopelessly corrupt Family Courts!

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My Letter to Evelyn Nissirios

If She Thinks She Can Weaponize the Law….

… What does she think will happen when we weaponize the Truth?

National media outlets and investigators are now closing in on the organized crime of the Family Courts. People are finally figuring out that these so-called “Courts” have been getting away literally with murder, wielding their unlimited judicial power against the most vulnerable and powerless members of society: innocent children and their loving caregivers. Why? For no other reason than that they are the easiest prey! It is the most cowardly, contemptible, and corrupt thing I have ever seen. I sent the following letter to the “guardian ad litem” who filed for an absurd protective order, stating that the public education articles I wrote — which she would have to look up the Internet to find — were “harassment” and “stalking”! What, then, do we call her trafficking of children to their abuse, torture, rape, battery, attempted murder, attempted suicide, and pedophilic sex rings? Michael Antoniewicz is the judge who granted her shameful application, for which he is being sued.

Dear Counsel for Ms. Evelyn Nissirios:

Please accept this as a formal notice and demand pursuant to Rule 1:4–8 and N.J.S.A. 2A:15–59.1 that Ms. Evelyn Nissirios (“Plaintiff”) voluntarily withdraw the Complaint that she filed in the above matter, in her own Division where she works, on June 8, 2024 (“Complaint”), with a judge she has extensively worked with in the past, Judge Michael Antoniewicz, under representation by her law firm, which has extensive business with this very Court.

It is respectfully noted that far too many assertions by Plaintiff are based on documented perjury, lack a good faith basis, and/or are allegations that are unsupported by facts or established law. Her latest filing of legal gibberish only further confirms that she willfully contorted and extended the Victim’s Assistance and Survivor Protection Act (VASPA) into areas it was never intended to enter, in order to serve her hidden aim of distracting and deflecting from accountability for her own acts of harassment and assaults — for which she has falsely claimed, “absolute judicial immunity.”

I request that Plaintiff no longer waste my time and Court resources but withdraw her frivolous Complaint in its entirety within seven (7) days of receipt of this written demand. If not, I will file for appropriate sanctions under my Federal Complaint, including full attorneys’ fees and costs in all related matters including but not confined to this Complaint. Ms. Nissirios may also face Racketeer Influenced and Corrupt Organizations Act (RICO) charges, 18 U.S.C. §§ 1961–1968, as well as a Class Action Lawsuit, FRCP 23, which I am in an excellent position to pursue with other, similarly victimized litigants, if she insists on continuing her flagrant abuses of the Law for nefarious, self-serving purposes. Counsel for Ms. Nissirios and Ms. Nissirios are both attorneys who should know better than to exploit the VASPA in a way that has absolutely no chance of succeeding in any other, non-corrupt circumstance.

Plaintiff has a long history of relying solely on conflicts of interest and disqualifying connections within a judicial system widely evaluated to be hopelessly corrupt. However, the cloak of impunity does not equal legality, and at some point she will no longer be able to escape discovery but will face the consequences of her trafficking countless innocent children to their documented torture, rape, battery, attempted murder, pedophilic sex rings, child pornography, and Satanic cults. Family Court may tolerate unspeakable levels of harm, but the rest of the world does not — and the only means of informing the public of the harm being done may be through the exercise of Free Speech rights under the U.S. Constitution.

I reiterate that the VASPA was never intended to circumvent the First Amendment or to avoid having to file a defamation lawsuit, just because one has no claim. Telling an inconvenient truth is not harassment, and the purpose of a judicial system is not to exist as a fraternity, purely to protect its own.

Ms. Nissirios’ Complaint principally arises from her feeling that every criticism is “harassment”, and every uncomfortable public appearance is “stalking”. However, a feeling is not fact. Instead, this is a projection of her own guilt, which is why I have recommended from the start a mental capacity evaluation for Ms. Nissirios, rather than a coddling of her criminal psychopathology. Indeed, no setting outside of a corrupt courtroom would uphold her delusional belief that objecting to her aiding and abetting kidnapping and attempted murder is “mere dissatisfaction” with her “services”.

There is a serious societal problem of the most predatory personalities congregating in Family Court, simply because innocent children and mothers are easy prey — and Ms. Nissirios is a quintessential example. Filing for a protective order against her victims to “reverse victim and offender”; to continue to pursue her lust for cruelty against innocent victims; and/or to conceal her crimes by silencing and harassing truthtellers is not a valid reason for filing a VASPA Complaint.

Conclusion

Pursuant to Rule 1:4–8 and N.J.S.A. 2A:15–59.1, Ms. Evelyn Nissirios is sanctionable for frivolous litigation, based on:

a. Initiation of litigation in bad faith, for the purpose of harassment, malicious prosecution, and malicious injury to another (to Defendant Patricia Lee, as her two hospitalizations and one admission to the intensive care unit prove).

b. The action was based on perjury and legal contentions that are not warranted by the spirit, intention, or logic of existing law but on bad-faith disfigurement of the Law.

c. The action was without merit and not supported by any reasonable legal argument or factual basis.

If Plaintiff does not voluntarily dismiss her Complaint in its entirety within seven (7) days of receipt of this written demand, I will make an appropriate application for sanctions, including an award of counsel fees and costs in all related matters including but not confined to this Complaint. I will also proceed with all other legal measures available to me, including Civil and Criminal Complaints, through which I intend to recuperate the full damages and full accountability for her actions.

Neither this correspondence, its contents, nor any documents referred to shall be construed as a waiver or release, express or implied, of any claims, counterclaims, cross-claims, third-party claims, defense, causes of action, rights, or remedies which I, Dr. Bandy Lee, may have at law, in equity or otherwise, all of which are expressly reserved.

Please be guided accordingly.

Very truly yours,

Bandy Lee, M.D., M.Div.

*All legal malfeasance and misfeasance connected to this case trace back to Family Court Judge Jane Gallina-Mecca, who performs a child theft operation linked to a 50- to 175-billion-dollars-a-year enterprise. Evelyn Nissirios is her disciple, and Michael Antoniewicz her subordinate judge. Please join our tremendous momentum to impeach Judge Jane Gallina-Mecca  — which has the potential finally to fix the hopelessly corrupt Family Courts!

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My Federal Complaint against Alan T. Chan and Peter M. Schoenfeld

Family Court Drags Everyone Down to Criminal Behavior — and Lawsuits May be the Only Remedy

I, my immediate, or my extended family had never filed a single lawsuit in all our lifetimes, but Family Court so multiplies illegal activity and human harm surrounding it, the causes of action have become incalculable. The following is an amended lawsuit, originally filed with the New York Supreme Court, which Alan T. Chan tried to tamper with by tricks of procedure (mainly by moving the case to federal court, without the amendment). I therefore wrote to the federal judge to clarify that my complaint was amended and copy it here:

COMPLAINT

Comes now Plaintiff, BANDY LEE, representing herself, and files this Complaint seeking damages and equitable relief against Co-Defendants ALAN T. CHAN and PETER M. SCHOENFELD, arising from the commission and aiding of fraud upon the court, in violation of New York common law and statutory principles.

PARTIES

1. Plaintiff Bandy Lee (hereinafter “Plaintiff”) is a physician and forensic psychiatrist practicing [and residing in New York]. Plaintiff provided financial and medical assistance to Co-Defendant Alan T. Chan’s ex-wife, Patricia Lee, in the form of a financial loan, and now medical assistance, for various marital obligations that were Alan T. Chan’s legal responsibility.

2. Co-Defendant Alan T. Chan (hereinafter “Co-Defendant Chan”) was employed as chief compliance officer for P. Schoenfeld Asset Management, a hedgefund company [located in New York]. Co-Defendant Chan was previously married to Plaintiff’s sister, Patricia Lee, and his actions have caused Plaintiff significant financial loss and harm, including the need for substantial medical assistance.

3. Co-Defendant Peter M. Schoenfeld (hereinafter “Co-Defendant Schoenfeld”) is the Founder, Managing Member, CEO, and CIO of P. Schoenfeld Asset Management, [located in New York]. Co-Defendant Schoenfeld, as employer of Co-Defendant Chan, provided the financial means, including actions above and beyond simple payment of an employee for his services; had knowledge of Co-Defendant Chan’s financial as well as other domestic abuse; and aided and abetted Co-Defendant Chan’s financial and other fraud upon the court, so as to facilitate his domestic abuse, including legal abuse.

JURISDICTION AND VENUE

4. This Court has jurisdiction over this matter pursuant to the laws of the State of New York, where Plaintiff works and resides and where Co-Defendants worked during the events giving rise to this action, according to CPLR § 301 and CPLR § 302. The venue is proper in this County, in the borough of Manhattan, according to CPLR § 503, as both Plaintiff and Co-Defendant were located here and the events giving rise to this action occurred in New York.

FACTUAL ALLEGATIONS

5. Co-Defendant Schoenfeld played a large role in Co-Defendant Chan’s fraudulent misrepresentation of himself in a divorce case against Plaintiff’s sister, Patricia Lee, which resulted in her losing everything and his gaining everything, placing a substantial financial burden on Plaintiff, as her closest family member.

6. Co-Defendant Schoenfeld lent Co-Defendant Chan credibility through his employment as chief compliance officer, despite his history of financial fraud — for which his previous employer, Patriarch Partners, was fined over $38 million. This unwarranted credibility empowered Co-Defendant Chan to commit fraud upon the court, which included hundreds of documented acts of perjury being unchecked against evidence but taken as fact.

7. Co-Defendant Schoenfeld had extensive knowledge of and participated in Co-Defendant Chan’s fraud upon the court, as he helped Co-Defendant Chan to hide, withhold, or advance money on his request, in order to help him maneuver an unjustly favorable outcome for him in his divorce.

8. Co-Defendant Schoenfeld had full knowledge of Co-Defendant Chan’s financial abuse of his ex-wife, in the context of considerable awareness of his domestic abuse, which included child endangerment, as a result of Patricia Lee’s and Plaintiff’s direct communications to him.

9. Co-Defendant Schoenfeld’s enabling of Co-Defendant Chan’s abuses were so concerning, several friends of Patricia Lee and of Plaintiff wrote to Co-Defendant Schoenfeld directly.

10. Co-Defendant Schoenfeld was investigated by the U.S. Securities and Exchange Commission (SEC), adjudged guilty, and sanctioned, specifically for failing to monitor or to supervise the fraudulent conduct of Co-Defendant Chan, in his capacity as chief compliance officer for P. Schoenfeld Asset Management (See “Exhibit A”).

11. Over a period of nearly five (5) years, because of Co-Defendant Chan’s financial abuse of his ex-wife, Patricia Lee had to take out a loan from Plaintiff under a formal, written agreement, to cover marital expenses. These were expenses that Co-Defendant Chan was legally obligated to pay, and included but were not limited to house and status quo maintenance, legal fees, and medical costs, all with receipts and itemizations, as follows:

- House and Status Quo Maintenance: $352,228.03

- Legal Fees: $541,536.26 (all in defense against Alan T. Chan’s legal abuse)

- Medical Costs: $96,094.03

The total amount of these expenses is $989,858.32.

12. Without Plaintiff’s loan, Co-Defendant Chan’s ex-wife could have starved, been held in contempt for failing to maintain the marital house, or died from lack of crucial medical care.

13. Co-Defendant Chan was provided with invoices on a monthly or bimonthly basis, with an option to begin repayment at any time. The written agreement with his ex-wife required repayment upon her access to her assets or the conclusion of her divorce, whichever came first. However, Co-Defendant Chan’s fraud upon the court permanently prevented Patricia Lee from accessing any of her assets, depriving her of the ability to repay the loan….

14. Co-Defendant Chan’s fraud upon the court did not end with financial abuse. He took everything from his ex-wife, including her children, whom he seriously injured in the past, for which he was on a restraining order. Now, his ex-wife, who was their primary caregiver from birth, has not seen them for four years. This caused greater financial hardship to Plaintiff, as Co-Defendant Chan’s actions directly caused Patricia Lee’s perfect state of health and productivity to deteriorate into severe disability from a stress-induced, life-threatening medical condition, for which she was hospitalized eight (8) times, is now on seven (7) medications, and recently had to stay in the intensive care unit (ICU) for five (5) days. During this last admission to the ICU, ending on December 21, 2024, as a direct result of Co-Defendant Chan’s legal abuse, Patricia Lee could only be discharged under 24-hour, round-the-clock supervision and care until her situation improved. To this day, she has not recovered but only worsened as a direct result of Co-Defendant Chan’s ongoing legal abuse and endangerment of her children — e.g., recent reports of their failing to grow in four years, missing half of school, and orthopedic injuries have caused her great distress.

15. Plaintiff was forced to volunteer her time to provide the urgent medical care and supervision to Patricia Lee, which resulted in significant losses of international work, travel, and academic promotional opportunities for Plaintiff. This loss for Plaintiff is presently being valued at her standard rate of $5,000.00 per day.

16. As of March 10, 2025, Plaintiff claims a total of $395,000.00 for seventy-nine (79) days of providing round-the-clock care and supervision to Patricia Lee, which includes adjusting plans to remain in the country at considerable personal and professional cost.

17. Plaintiff has requested that Co-Defendant Chan repay the amounts due, including the loan for marital expenses and the additional care expenses. Co-Defendant Chan has instead blocked Plaintiff’s email address, such that she had to create new accounts each time to reach him. He also hid his work profile and then the fact that he had been laid off, which he has failed to report to the court for seven (7) months and ongoing, in order to continue his fraud upon the court. Co-Defendant Chan has also changed residences five (5) months ago, without reporting to the court as required by law — despite a history of absconding with the children — and was only recently located by law enforcement when a new restraining order had to be issued for threatening his ex-wife (See “Exhibit B”).

18. For almost the entire duration of the divorce action, Co-Defendant Schoenfeld employed Co-Defendant Chan, giving him credibility, the financial means, and assistance with moving money on his request, to enable Co-Defendant Chan not only to engage in legal abuse but to commit fraud upon the court for his unjust enrichment, at the expense of Plaintiff. Co-Defendant Chan made false testimonies under oath, submitted incomplete documents, and engaged in witness and evidence tampering with the false credibility Co-Defendant Schoenfeld gave him as chief compliance officer. Co-Defendant Schoenfeld was informed on numerous occasions about his employee’s conduct but failed to take reasonable steps to investigate or prevent potentially criminal behavior, in a similar way that caused him federal sanctions. Instead, Co-Defendant Schoenfeld actively aided and abetted Co-Defendant Chan’s financial and other abuse through fraud upon the court. As a direct result of Co-Defendant Schoenfeld’s and Co-Defendant Chan’s actions, Plaintiff suffered enormous financial loss, professional compromise, and emotional pain.

CAUSES OF ACTION

COUNT I — AIDING AND ABETTING FRAUD — SCHOENFELD

COUNT 2 — NEGLIGENT SUPERVISION — SCHOENFELD

COUNT 3 — FINANCIAL FRAUD UPON THE COURT — CHAN

COUNT 4 — UNJUST ENRICHMENT — CHAN

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that this Court:

(a) Enter judgment for Plaintiff on Counts 1–4.

(b) Award compensatory damages against Co-Defendants Chan and Schoenfeld in an amount to be determined at trial.

(c) Award punitive damages in an amount sufficient to deter Co-Defendants Chan and Schoenfeld and others from engaging in similar conduct

(d) Award Plaintiff equitable relief, including but not limited to the loan amount for marital expenses, totaling $989,858.32, and damages for the caregiving services provided, in the amount of $395,000.00.

(e) Award pre-judgment and post-judgment interest.

(f) Award the costs of suit and any attorney’s fees incurred in bringing this action.

(g) Award any other relief that the Court deems just and proper.

Dated: March 9, 2025

*All criminal activity in this case trace back to Family Court Judge Jane Gallina-Mecca, who performs a child theft operation linked to a 50- to 175-billion-dollars-a-year enterprise. This is because, wherever there is organized crime, ancillary criminal activities follow. Please join this remendous momentum to impeach Judge Jane Gallina-Mecca  — which has the potential finally to reform the corrupt Family Courts!

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Judicial Conduct Complaint against Judge Jane Gallina-Mecca

Will It Ever be Heard?

The following Complaint was submitted to the New Jersey Supreme Court Advisory Committee on Judicial Conduct. Yet, for months, there has not even been acknowledgment of receipt, let alone an investigation. Meanwhile, a second criminally-indicted co-conspirator of the judge has had her charges mysteriously removed. Prosecutors have remarked on the case: “I have never heard of such a thing before.” Yet, Gallina-Mecca has a track record of removing charges against murderers she supported, such that brutal killings end up without an investigation or even a suspect! Having done this for a decade, she literally has a trail of dead bodies behind her, but will the Advisory Committee on Judicial Conduct ever investigate? The most unspeakable crimes occur through the Family Courts, but they bring in more profit than all the other courts combined — and it appears that no judicial board is willing even to open an investigation on a human trafficking enterprise that sends up to 100,000 children to their torture and death every year….

AFFIDAVIT OF PATRICIA J. LEE

This Affidavit Complaint is declared as a duly sworn statement against Judge Jane Gallina-Mecca for her violations of the relevant sections of the Code of Judicial Conduct, the Fifth and Fourteenth Amendments of the United States Constitution, and the New Jersey Constitution’s Due Process and Equal Protection Clauses. It is supported by substantial evidence of bias, procedural irregularities, and statutory violations that question her impartiality and the integrity of the judicial process. Complainant Patricia J. Lee (hereinafter “Complainant”) states as follows:

I. Ex-Parte Communication and Judicial Misconduct

On November 12, 2021, Judge Jane Gallina-Mecca held an ex-parte conference with Plaintiff Alan T. Chan … (hereinafter “Plaintiff”) and Guardian ad Litem (hereinafter “GAL”) Evelyn Nissirios to strip Complainant of her custody of her children without time limit. First, the Judge acted with “cold indifference” when she denied Complainant her first-time request for an adjournment, despite her suffering from a life-threatening medical emergency and despite her submitting a doctor’s note — which was later corroborated with medical records from the emergency room, where her symptomology was so severe, she was tested for a heart attack. Second, the Judge convened an ex-parte conference on “emergent application” by GAL Nissirios, without notice to Complainant or Complainant’s attorney, in which she issued an order transferring custody from Complainant to Plaintiff without warning, cause, statement of reason, or due process (Complainant’s custody was never in question, whereas Plaintiff was only recently regaining custody following a temporary restraining order for slamming his son’s head against a window). Third, a transfer of custody was ordered without any finding or even suggestion of a problem with Complainant’s parenting, which hitherto had an impeccable track record, where the children thrived physically, emotionally, and academically under her full-time care. Even after at least two (2) psychiatric experts reported that Complainant has “exceptional talent in parenting,” following extensive collateral interviews of other adults and parents who observed her and knew the children — interviews that GAL Nissirios notably did not perform — Complainant’s children were not returned to her….

A. Legal Standard and Analysis

[Violation of Judicial Canons, U.S. and State Constitutions, Case Law, and Rules of Evidence, as well as Documented Bias, demonstrated in over two thousand (2000) pages of evidence.]

II. Allegations of Judicial Partiality, Ethical Breaches, and Due Process Violations

The involvement of Judge Jane Gallina-Mecca in proceedings concerning Alan T. Chan and Patricia Lee raises significant concerns of judicial partiality, ethical violations, and due process breaches. Top-quality evidence, including six (6) highly-qualified medical experts warning of Plaintiff Chan’s dangerousness to his children and his spouse, and two (2) additional highly-qualified child psychiatrists alarmed about the “invariably highly detrimental” separation of young children from their primary caregiving mother, suggests potential judicial impropriety, undermining public confidence in the judiciary. These issues are further compounded by Judge Gallina-Mecca’s approval of an unlicensed, unsupervised, and unqualified “associate counselor,” who contradicted ten (10) highly-qualified doctorate psychologists and psychiatrists, because the “associate counselor” concluded in her unqualified “assessment” that some of Complainant’s answers were “tangential” — which GAL Nissirios then erroneously interpreted to mean that Complainant was “mentally incompetent.” No amount of clarification by highly-qualified psychiatrists that “tangential” speech is a normal sign of trauma, and that Plaintiff’s violent abuse must be looked into, could change her mind.

Furthermore, the Judge insisted that Complainant needed another psychiatric evaluation, against ten (10) highly-qualified psychiatric experts who reported that she has “excellent mental health” and explicitly stated that she did not need another psychiatric evaluation — and against the recommendations of her own appointed guardian ad litem for Complainant, Linda Schofel, who completed a thorough investigation and concluded that Complainant was mentally competent and in need of no further evaluation. Further demonstrating her bias, the Judge promptly fired GAL Schofel for faithfully performing her job. [GAL Nissirios was kept on, but when] confronted with her six hundred (600) documented lies and acts of perjury, she resigned, since her testimony is the sole reason two (2) children were transferred to the father who almost killed each of them. The Court’s blatant bias for Alan T. Chan’s interests and hidden financial agendas, while systematically disadvantaging Patricia Lee, needs to be scrutinized for its breaches of ethics and violations of due process.

A. Legal Standard and Analysis

[Violation of Judicial Canons, U.S. and State Constitutions, and Case Law, as well as Procedural Misconduct and Disregard for Evidence of Perjury and False Testimony, evidenced in six hundred (600) documented lies and acts of perjury]

III. Violation of Title 42 U.S.C. § 1983

Title 42 U.S.C. § 1983 provides remedies for individuals whose constitutional or federal rights have been violated by persons acting under color of state law, including judges, when their actions exceed judicial immunity. Judicial immunity does not apply when a judge’s conduct is outside the bounds of established law or is motivated by bias. Judge Gallina-Mecca’s documented conduct demonstrates a pattern of bias, actions outside the bounds of established law, and disregard for Complainant’s constitutional rights to fair process and impartial judgment, creating liability under § 1983. There is also a federal lawsuit in effect under this Code since August 2023. Under 28 U.S. Code § 455, judges are required to recuse themselves from any proceeding in which their impartiality might reasonably be questioned, including being sued under 42 U.S.C. § 1983, but so far Judge Gallina- Mecca has refused to recuse herself.

A. Legal Standard and Analysis

[Violations of 42 U.S.C. § 1983, Established Law, Criminal Codes, and Judicial Canons, revealed in over two thousand (2000) pages of medical records, expert reports, police discovery evidence, and photographic documentation.]

IV. Weaponization of Judicial Process to Endanger Lives

Judges in New Jersey are beholden to human rights laws and ethical standards that require them to uphold the rights and dignity of individuals involved in legal proceedings. This includes the U.S. Constitution, the New Jersey Constitution, and international human rights treaties. Additionally, the New Jersey Code of Judicial Conduct holds judges to ethical standards that support the fair treatment of all parties and the promotion of justice. Yet, alarmingly, Complainant’s and her children’s human rights have been flagrantly violated in Judge Gallina-Mecca’s courtroom to the point of endangering their lives. Complainant brushed with death eight (8) medically-documented times during the course of this litigation. She suffered four (4) life-threatening hypertensive crises in just the past six (6) months from the stress from this litigation, with her second (2nd) hospital admission during the holidays requiring five (5) days in the intensive care unit. Prior to the Court’s interventions, which specifically enabled and augmented Plaintiff’s violent attacks against his family — including the violent abduction of his children and the total withholding of them for the last four (4) years from their mother, who was their primary caregiver since birth — Complainant was in a perfect state of health. All physicians and medical expert witnesses of her condition — now with permanent brain and heart changes from her stress-induced high blood pressures — offer no cure for her other than “justice”….

A. Legal Standard and Analysis

[Violations of International Laws, U.S. and State Constitutions, 7 Canons and 22 Rules of Judicial Conduct, and 4 Protected Characteristics of Anti-Discrimination Laws, shown in over two thousand (2000) pages of doctors’ reports, hospital records, and police discovery evidence, in addition to audio recordings.]

V. Summary of Judicial Bias and Misconduct

Judge Jane Gallina-Mecca’s conduct in this case demonstrates repeated violations of the canons of judicial ethics, undermining the principles of impartiality, fairness, and public confidence in the judiciary. Canon 1 was violated when Judge Gallina-Mecca colluded with a duly-diagnosed psychopath and violent perpetrator to “legalize” his kidnapping of his children through deceit, lies, and perjury. Canon 2 was violated when Judge Gallina-Mecca personally attacked and character- assassinated Complainant in order to traumatize her and discredit her as a witness. Canon 3 was violated when Judge Gallina-Mecca displayed blatant bias for Plaintiff, engaging in ex-parte communication and ruling exclusively in his favor over four-and-a-half (4.5) years, and never in Complainant’s favor. Canon 4 was violated when Judge Gallina-Mecca abused her judicial position to engage in tampering of evidence, fabrication of false “evidence”, and witness intimidation and retaliation outside her courtroom, which undermines the viability of a justice system. Canon 5 was violated when Judge Gallina-Mecca interfered with every other agency, court, or the press, in an attempt to shape the outcome of this case, which left no institution independent of her. Canon 6 was violated when Judge Gallina-Mecca allied 100 percent with the monied party, so that he could gain everything from the divorce and be so grateful for his illegitimate gains, that he would be likely to contribute handsomely to the Judge’s campaign. Canon 7 was violated when Judge Gallina-Mecca ordered that public criticisms of her be “immediately removed, deleted, and unpublished immediately,” which is also a violation of the First Amendment protections of a free press.

CONCLUSION

Based on Judge Jane Gallina-Mecca’s conduct in this case — including procedural improprieties, repeated denial of due process, reliance on unverified testimony, violation of statutory protections, arbitrary legal standards, assistance of criminal acts, and bias against Complainant and expert witnesses who would give truthful testimony — sanctions against her are mandatory. Further, Judge Gallina-Mecca’s removal from the bench needs to be considered for her repeated and demonstrable stretching of the facts and torturing of law and procedure to achieve her predetermined, personally-committed ends. As Chief Judge of the Bergen County’s Family Court system, she needed to set an example that is critical to any impartial and just judicial system that preserves its integrity and independence — but egregiously failed.

WHEREFORE, Complainant Patricia J. Lee requests that a formal and immediate investigation be pursued without interference from the Judge and without fear or favor, for her failure to enforce procedural evidentiary standards; her serving as her own witness in a case she was presiding over; her scheduling of unwarranted ex-parte hearings; the appearance and demonstration of incontrovertible bias; due process violations; and lack of fairness … to cause immense suffering, medically-documented torture of children, and multiple near-death episodes for Complainant, the mother of these children.

Additionally, systemic reforms in New Jersey’s Family Court may be recommended: the judiciary should implement training, oversight, and accountability measures to address systemic bias for abusive (often sadistic, violent, and cruel) parents over protective (often loving, nurturing, and devoted) parents in family court proceedings, which can lead to catastrophic harms to children and families. Family court practices that blatantly violate local, federal, and international law to privilege “pseudo-science” over sound medical expertise have been denounced by multiple medical associations as well as the United Nations Human Rights Council and the International Criminal Court…. No system should reward or allow to prevail conduct of the kind that Judge Jane Gallina-Mecca has repeatedly and overwhelmingly demonstrated over multiple years in this case, and across dozens of other, near-identical cases in Bergen County Family Court.

[An Appendix of thirty-three (33) pages contains direct quotes and statements, in Gallina-Mecca’s own words, that decisively incriminate her and unequivocally prove the above without room for doubt.]

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There are No ‘Winners’ in Family Court

How Family Court Victimizes Even ‘Winners’ — and My Brother-in-Law is a Primary Example

I have a brother-in-law who is a diagnosed psychopath. He fooled me as well. Most people consider psychopaths to be scary, but they simply have a personality disorder that is easily lured into crime; they are not criminals by nature. They are lured into crime, because they do not understand human love — only that they are outside of it — and their expression of their longing is to reject it and harm it.

In my view, there is no such thing as a “successful psychopath”; a masterful appearance of success is still not success, no matter the ladders one may climb, and threatening and conning everyone into believing that one is a terrific parent does not make a true parent for the children. Ideal appearances and external actions do not compensate for the internal havoc one wreaks, wherever one goes.

This is why I call psychopathy, “the most debilitating disorder in all psychiatry.” If one had schizophrenia, at least one’s humanity can emerge once the symptoms are treated. With psychopathy, because afflicted persons deal with their lack of humanity not by working on themselves but by building an impeccable façade of the opposite, there is almost no way to reach them. But there is always something one can do: one can set limits, carefully work on behavior so that the person can participate in society without causing harm, and maybe some true satisfaction can emerge.

Family Courts, unconscionably, do the opposite. They prey on this vulnerability in psychopathic personalities by promising them unlimited power and financial rewards — if only they took the children! The depravity behind sacrificing children for profit — using authority to plunder rather than protect the most vulnerable in society — is why I call Family Courts, “a culture of psychopathy.” Of course, psychopaths are very sick individuals, and handing them their fantasy descends them into magalomania, magnifies their violence, and may result in murder, suicide, and murder-suicide, as we so commonly see.

Hence, truly, shame on Family Courts.

My brother-in-law had a reason to feel perplexed. His wife had a relationship with her children that was the envy of anyone who observed them. Even other children noticed: “Wow, you have that with your mom!” He married her because this was what he yearned for, but he tried to seize what he did not have by pretending, and with children, a masterful imitation of humanity, empathy, and compassion does not replace the real thing.

This is how the inside story came to be so terrifying. My brother-in-law’s divorce was not so much a decision as a panicked reaction to being “found out.” He did not know that, when someone cries out in pain, it is not a personal attack on him — it just means the person is in pain. Out of aggrieved expectations and entitlement, he started taking ruthlessly and, startled at how little he was left with, he responded by taking even more — but that is not how human relationships work. Hence, he ended up injuring his children, kidnapping them to hide his injury, and almost killing their mother numerous times.

These are the pathological dynamics Family Courts magnify and even manufacture, where the problem becomes cancerous and metastasizes. It is ironic that they are allowed to bring the psychological equivalent of brass knuckles and crowbars to the most unsuspecting, innocent children and mothers who enter — expecting justice — who are suddenly shocked to discover that they are being bludgeoned if not killed. They typically never recover enough to fight, which further helps Family Courts hide their atrocities.

Psychopathic spouses may watch this with delight, but they do not know that they are only harming themselves. The smart ones leave the trap altogether, attenuate their destructive drives, and compromise at a level closer to reality, before it is too late. I still hold out hope that my brother-in-law will be smart.

Dear Alan,

You have now been served my lawsuit. This is just the very first of many, unless you decide otherwise. The choice is yours.

Have you realized by now that you have been duped by a corrupt court? You were led into believing that you could have everything, and Patricia nothing.

Notwithstanding all the money you have spent on players in your corrupt court — not to mention on compromising them with money under the table — there is no way Patricia is constitutionally capable of making the kind of money you are demanding.

The bottom line is that, despite the many promises they made to you, you have been taken for a ride. There is almost no possibility that the sham rulings of this corrupt court will not be thrown out when we are through with you.

There will be all kinds of unintended costs you have not factored in — and for all that you have spent for nothing, you could have supported your children for the next one hundred years! Hence, if you were smart, you would cut your losses. You would be reasonable and compromise, not continue to escalate your war against your family,

every time your self-inflicted wounds cause more losses. Your fantasy of gaining “everything” will never come to pass — and no amount of conning, lying, gaslighting, and contorting will alter reality, and the Truth will catch up with you.

Let the Truth set you free instead.

All your life, you have wanted to experience love. You will never have that experience until you learn to give love.

You were lucky to have a wife who is not greedy, who would have gladly done all the hard work of raising your children, and help you to have a great relationship with them in ways that all your abducting, isolating, coercing, and “brainwashing” could never do (it is not as easy as you thought, is it?).

Right now they have to pretend, as they are your prisoners, but it is a given that, when those children turn eighteen, they will never forgive you for what you have done. No matter what stories you conjure up, they will never forget your separating them from their mother — without giving them even one minute with her!

The irony is that, ultimately, it is really you who have lost your children, for holding them hostage in your house. And you dealt with their discontent by forcing them to smile, not even giving them the freedom to feel what they feel!

You do not really want these children. If you really wanted them, you would not have made an emergency recruitment of your father to fill the role as you abandoned them.

Look at your children: they stopped growing. That is a sign of extreme trauma! Any psychologist would tell you that abruptly and totally depriving children of their mother, just because you wish to punish her, is irreparably damaging for children.

X and Y do not even look like children; they look like two waifs or concentration camp inmates. If you really wanted them, if you loved them, they would not look the way they do. And there are sources that have informed Patricia of the unspeakable abuses they have endured from you.

The real irony is that, all your life you wished to experience love — but all you have done makes it impossible for you to experience love. You had the fortune of having the most loving wife and the most affectionate children one could imagine — and all you did was punish them for having what you did not have in your childhood.

Please, do the right thing, and maybe — just maybe — you can redeem yourself in the eyes of your children as well as of God, whom you seem to believe you can mock.

Keep at this, and you will come to know that the biggest victim is you!

One of the people who deluded you and colluded with you that you could have “everything” is Evelyn Nissirios. Sooner or later, she will not be able to deflect all lawsuits coming at her with her “judicial immunity,” and she will have to enter discovery. Do you know what will be revealed? Dozens of children trafficked to their torture, battery, attempted murder, rape, pedophilic sex rings, child pornography, and Satanic cults, in the most depraved way! This is the company you have kept and trusted, above your own family!

And the extreme degree to which Jane Gallina-Mecca has aided and abetted you with extreme bias — the exact opposite of what a judge is supposed to do — is now about to get her disrobed.

What you might succeed in doing is causing Patricia’s physical demise, and I promise you, if this should come to pass, I will make sure that you will be held responsible for murder. And, above all, both your children will know who is responsible for her death.

If you expect your children to take care of you in your old age, you may be shocked to discover that they will not give you the time of day.

Wake up, Alan! We were never your enemy, but you insisted on making yourself ours, and this does not serve you.

How sad, pathetic, and tragic that, after seventeen years of marriage to a woman who gave you everything she had, you now hate this woman who is incapable of hatred but can only love. How sad! How tragic for Patricia, the children, and most of all for you!

Here is your choice: we can continue this process in appellate court, civil court, criminal court, and the U.S. Supreme Court until you receive your just reckoning, or you can do the right thing and settle this in a fair and equitable manner.

It is a given that we will be in court for however many years it takes — five, ten, fifteen — until the children are returned to their mother. And the house you intend to seize — come hell or high water — will be the least of what you owe me.

You are not wise enough at this point to know what you will ultimately realize — that what you did to your wife and children, you did to yourself.

What you do not understand is that this court, pretending to support you, has made a fool of you, draining all your funds and hemorrhaging all your money. Can you see that Evelyn Nissirios and Jane Gallina-Mecca took you for a sap — a fool’s fool? What this court has “awarded” you will never come to pass, because no legitimate appellate court that operates with integrity will uphold it.

You should be able to see now that you would have been way ahead of the game, had you settled this five years ago as a responsible husband and father. There are countless examples of children who disown their parents after years of abuse in this way. If you are counting on your children to take care of you in your old age, you may be in for a rude awakening.

The solutions are all before you. We could resolve in a day what your court could not solve in the last five years, and what will be challenged over the next fifteen years.

There is still time, a last opportunity for you to rectify the situation. Otherwise, we all suffer. You have almost killed Patricia, you have taken years off of your father’s life, and frankly you have broken my own father’s heart: you almost killed three people!

You have taken years off the life of your father and my father, and the two children in your house are suffering a slow death. I thus appeal to you to do the right thing, and let this be over for all of us. If you do, then perhaps for the first time in your life, you will experience love.

I am not your enemy. What I am expressing to you is the only possible way that we could all heal. We are all in need of healing, and especially you, Alan.

Love,
Bandy

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My Letter to School District Superintendent Michael Schwarz

Family Court Corruption Corrupts All Bodies It Touches

A letter arrived from my niece’s school that she has missed an inordinate number of days of school: 16 so far. Four years since her savage abduction and imprisonment by her violent father — and Judge Jane Gallina-Mecca’s giving him full custody to help him hide his brutal crimes — she has never recovered the perfect attendance she had under her mother. At least a letter arrived — but will anyone do anything? When she missed 56 days of school in about the same period, four years ago, then “Principal” Michael Piacenza covered it up, tampered with computer records, and falsely arrested concerned professionals instead. At least he has been demoted to his previous position — but will anyone actually protect an innocent child? Few can imagine Family Courts to be the auctionhouses and the slave trade of children that they are, and therefore the fallback is to force oneself into the conviction: “There must be something wrong with the mother”; or “The child looks all right” — even though, as in my niece’s case, she has hardly grown physically in four years. But as society looks away, numbers do not lie: a thousand children are documented to have been murdered because of Family Court, a similar number to have committed suicide because of Family Court, and hundreds of thousands more to be suffering “soul murder” in silence because of Family Court. Below is my letter to the school district superintendent:

RE: Pupil in Your School District, Grade 7

February 27, 2025

Dear Mr. Michael Schwarz:

I am contacting you again because, in spite of the circumstances of our first meeting, you have come across to me as more discerning than most school officials, and thus capable of understanding the seriousness of the situation.

As you may know, I have federally sued Mr. Michael Piacenza for covering up signs of child abuse, tampering with school absence records, and falsely arresting me and a renowned forensic psychiatrist for attempting to fulfill our legally-mandated duty to report child abuse. I do not wish to take action against the entire school.

Certainly, a school exists to protect children, not to harm them. It can be misled when a corrupt judge assists in facilitating child abuse because it is profitable, but this is all the more why we need to protect children, who are voiceless in society and easily exploited. Child protective services, which should be independent, are often under the thumbs of family court judges.

The judge in this case is in the process of being referred for impeachment, as attached, for sending dozens, if not hundreds, of children to their rape, battery, attempted murder, and child sex trafficking. It is being guided by one of the nation’s top constitutional lawyers who impeached three U.S. presidents.

Also, you may wish to know that Alan T. Chan’s employer let him go, as a colleague of mine who wrote the attached letter informed me. I am also attaching my recent affidavit (the criminal charges I am bringing against him are at the end), as well as my lawsuit against him for his financial enrichment schemes — which are the true reason behind his abducting the children. Also for your reference are the federal sanctions Alan T. Chan’s employer has come under because of his financial fraud, and his temporary restraining order for his violence against his ex-wife.

Children are vulnerable. This is why educational and medical professionals have an independent duty to investigate as well as to report child abuse. The pediatrician who detected abuse in this case but chose to cover it up instead has now been criminally indicted and may even lose her license. I therefore urge you to do what is right; profit or mere convenience does not last very long, whereas injury to a child lasts a lifetime.

Cordially yours,

Bandy Lee, M.D., M.Div.

—

Attachments:

Mr. Peter Schoenfeld,

I am writing to bring to your immediate attention a matter of grave concern involving one of your key employees, Alan Chan, whose conduct toward his now former wife, Patricia Lee, and their two young children, has raised very serious issues of many kinds, including legal. Given Mr. Chan’s position within your organization, it appears that his continued employment with you may have facilitated and quite likely enabled the extremely troubling behavior in question. From what I have learned, this matter, if not addressed promptly and thoroughly, could expose your organization to significant risks, both legal and reputational.

I strongly urge that you initiate a full investigation into Mr. Chan’s actions, as it appears to me the potential for serious consequences to your organization is great. There are notable precedents where similar situations have resulted in substantial financial and reputational damage. One such case is that of Allan Kassenoff, formerly employed by the law firm Greenberg Traurig. Once details regarding his conduct became public, the firm was forced to sever ties with him and to address the situation via this carefully prepared statement, no doubt after realizing it had to fire him and protect its own reputation and integrity, I imagine with some kind of agreement that prevented legal action and much greater negative consequences and notoriety:

“The firm has concluded its review of the situation to determine Allan Kassenoff’s status with the firm. Our primary obligation is to maintain and protect the core values and best interests of our firm, our clients, our lawyers and our professional staff. Allan has been on a short leave of absence and has now resigned from the firm, effective immediately. The firm is sensitive to the needs of the three children, the primary victims of the situation, and therefore will be creating a dedicated trust fund with an independent trustee for the sole benefit of these children, to be voluntarily funded by the lawyers and staff of our firm. We wish healing and privacy to the children during this very difficult situation.”

I refer you to a couple of articles that summarize that situation:

https://msmagazine.com/2023/06/12/allan-kassenoff-resigns/ https://msmagazine.com/2023/06/20/catherine-kassenoff-family-court-divorce-bandy-lee/

I have become aware of this matter through my longstanding association with Dr. Bandy Lee, a distinguished professional (https://bandylee.com) whose integrity and stature in her field are impeccable and beyond reproach in all regards. At my request, she has shared with me some details of this situation with her sister, niece, and nephew caused by the deeply troubling pattern of completely false accusations and the outrageous manipulations of the Family Court system by Alan Chan. Introduced by Dr. Lee, I have also come to know her sister, Patricia Lee and as a result have looked into this whole matter in detail. I can with total surety attest to her exemplary character and the profound injustice and unconscionable wrongs she has suffered by the contemptable actions of your associate, Alan Chan.

Among other things, Dr. Lee is a New York Times bestselling author, and my understanding is that she is working on an exposé of the Family Courts that have been corrupted enough for Alan Chan to weaponize unconscionably and unjustly against his family. That in itself is a matter of considerable public importance, which I know Dr. Lee and others are currently pursuing, in the form of a documentary and a television series, not to mention possible major media appearances once Dr. Lee’s book is out. I have reviewed very extensive, now publicly available legal filings about this situation and urge you to do so also. Among the information publicly available are Dr. Lee’s writings on her Medium publication (https://bandyxlee.medium.com/) and her books, Exposing Family Court and Judicial Violence: Anatomy of a Family Court Case, which are available on Amazon (my understanding is that the big book is still coming).

Dr. Lee has been in consultation with several prominent legal figures, including Laurence Tribe, Professor Emeritus at Harvard Law School, and Bruce Fein, among the best-known and most respected attorneys in Washington, who have expressed deep concern over what Alan Chan has done so grossly and wrongly, and how his ongoing association with your firm has facilitated his egregious actions. Given the severity of the situation, I believe it is imperative that you take immediate action to investigate Alan Chan’s past and current conduct and determine the appropriate course of action under all the circumstances, including a recent court-ordered legal restraining order issued against him.

I do not know if you have previously been aware of this serious situation in which your firm is so involved, but now with this communication there is no excuse for your not knowing and not acting. Failure to respond in the face of such information would be not just morally wrong but I think quite possibly legally implicating for you. Failure to take action now could indicate a gross lack of accountability, serious disregard for the extreme abuses against his family caused by Alan Chan, a lack of due and required professional diligence, and complicity by yourself and your firm with Alan Chan, who has been your associate for many years. Though I do not practice law myself, I do have a J.D. degree from NYU Law School, where I was a prestigious Root-Tilden Scholar, and after extensively looking into this matter I have become aware of what seem to me serious potential liabilities and ramifications for your firm. Consequently, I strongly encourage you to address this matter with the urgency and seriousness it warrants, before it is too late, to avoid what may now happen in both the courts of law as well as media and public opinion that could substantially involve and impact your firm.

Taking everything urgently into consideration, I trust that you will quickly take the necessary steps to investigate this matter thoroughly and take appropriate actions. Please consider this communication as a formal request for your prompt response, as two children and an ex-spouse are literally in mortal danger, even as Alan Chan is on a restraining order, because of his ability to maneuver the courts. I have sent this letter via receipted delivery, and I ask that you contact me by email, phone, or mail within three days of receiving this information. If you would like, I can and will provide additional information and assistance to you, your firm, and any legal or media representation you may have. Should I not hear from you, however, I will be forced to conclude that further steps are necessary, including contacting additional individuals and entities associated with your organization.

N.C.

—

CRIMINAL CHARGES AGAINST ALAN T. CHAN (from the Affidavit of Bandy Lee, submitted on behalf of Patricia Lee under Durable Power of Attorney, due to Family Court-caused disability)

N.J.S.A. 2C:33–4. Harassment

N.J.S.A. 2C:12–1. Aggravated Assaults

N.J.S.A. 2C:5–1. Criminal Attempts at Homicide

N.J.S.A. 2C:14–2. Sexual Assaults

N.J.S.A. 2C:15–1. Robbery

N.J.S.A. 2C:18–2. Burglary

N.J.S.A. 2C:12–3. Terroristic Threats

N.J.S.A. 2C:17–3. Criminal Mischief

N.J.S.A. 2C:12–10. Stalking

N.J.S.A. 2C:13–5. Criminal Coercion (as Added to the Prevention of Domestic Violence Act of 1991)

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DR. BANDY LEE FILES LAWSUIT WITH IMPEACHMENT INITIATIVE TO BRING TRANSPARENCY TO STAR CHAMBER-LIKE…

DR. BANDY LEE FILES LAWSUIT WITH IMPEACHMENT INITIATIVE TO BRING TRANSPARENCY TO STAR CHAMBER-LIKE FAMILY COURT

Press Release — For Immediate Distribution

New York City

Contact: (917) 328–2492

Family Courts are notoriously secretive, like the Star Chamber in England, which was abolished approximately four centuries ago.

Transparency is indispensable for deterring Family Court abuses, including judicial bias or witness perjury.

Dr. Bandy Lee’s lawsuit, filed in the United States District Court for the District of New Jersey challenges the constitutionality of the secrecy cloud that hovers over Family Courts nationwide. The Judge in Dr. Lee’s case censored her writing about Family Court proceedings, ordering it removed from the Internet and holding her in contempt under threat of imprisonment if she speaks or writes about the serious abuses she has professionally witnessed— a prior restraint in blatant violation of the First Amendment.

Both Doctor Lee and her constitutionally acclaimed Attorney Bruce Fein are available to media — bandy@bandylee.com & bruce@feinpoints.com.

Dr. Lee has appeared on many media programs and authored bestselling books. Much has been written about her, including this major article: “The Psychiatrist who Warned Us that Trump would Unleash Violence was Absolutely Right,” and many others linked at her website BandyLee.com.

Chief Judge of Family Court Jane Gallina-Mecca, who tolerates chronic abuses of due process and free speech violations, in order to hide gross human rights violations, will be referred to the New Jersey Assembly to consider impeachment proceedings guided by Mr. Fein.

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Long Version:

DR. BANDY LEE FILES LAWSUIT TO PROTECT FREE SPEECH

IMPEACHMENT TO FOLLOW

New York City

Contact: (917) 328–2492

Psychiatrist and medical doctor, Bandy X. Lee, M.D. (bandylee.com), has just filed an important First Amendment case in the United States District Court for the District of New Jersey. Famed constitutional lawyer and scholar, Bruce Fein, Esq., is her attorney from Washington, DC.

Both Doctor Lee and Attorney Fein are available to speak with the media about this important matter — bandy@bandylee.com & bruce@feinpoints.com

Dr. Lee previously boldly stood up to Yale University — where she taught at the medical and law schools for 17 years — at the very onset of academic censorship and violations of Free Speech in our era. She has been applauded for doing so by a large number of legal scholars and fellow psychiatrists, including such renowned persons as Harvard Law School Professor Laurence Tribe, former White House Chief Ethics Counsel Richard Painter, and eminent psychiatrists and other professionals.

Dr. Lee became nationally known for her bestselling book, The Dangerous Case of Donald Trump: 37 Psychiatrists and Mental Health Experts Assess a President. She has appeared on many media programs and has written a number of other important books, all available on Amazon. Much has been written about her, including this major article: “The Psychiatrist Who Warned Us that Donald Trump Would Unleash Violence was Absolutely Right,” and many others linked at her website, BandyLee.com, or that of the World Mental Health Coalition, of which she is President.

Now, Dr. Lee is again fighting for Free Speech. She has filed a federal case because a dangerously corrupt and grossly unjust Family Court in New Jersey is attempting to censor her writings, ordering them removed from the Internet, and holding her in contempt under threat of imprisonment if she speaks or writes about the serious abuses she has professionally witnessed and uncovered.

Far from adjudicating the Law, Family Courts ironically function more like criminal enterprises, where the most heinous crimes are being committed against the most vulnerable members of society with impunity. Thousands of children and women have died unnecessarily, and hundreds of thousands of others have endured unspeakable suffering.

Shortly after Dr. Lee began speaking about the horrors she was witnessing in the Family Court system, she was stalked, harassed, and at one point falsely arrested. It was very apparent to her that she had become a threat to a corrupt 50-billion-dollars-a-year enterprise.

She came to the recognition that abuses in Family Courts are above all a First Amendment problem. She notes: “There is a reason why Free Speech is in the very First Amendment of the U.S. Constitution, as the first defense against abuses of power.”

Attorney Fein notes: “Family courts are notorious for discounting claims of domestic violence against women and minors. The phenomenon has been meticulously documented by the Human Rights Council of the United Nations General Assembly, 53rd session, 19 June-14 July 2023, Agenda item 3, Report of the Special Rapporteur on violence against women and girls, its causes and consequences, 13 April 2023.”

For the past two years, Dr. Lee has been investigating the severe abuses of power in the Family Courts throughout America, having become aware of the situation through her sister, who lost custody of her children without fault or due process to a compromised Family Court and then was undermined, financially drained, and targeted to the point where her life was threatened, so that she could not fight back.

The District Court lawsuit just filed is brought against a judge who ordered the unconstitutional takedown of articles about these abuses. Chief Judge of Family Court Jane Gallina-Mecca, who tolerates chronic abuses of due process and free speech violations, in order to effectuate gross human rights violations, will be referred to the New Jersey Assembly to consider impeachment proceedings. Attorney Fein, who helped impeach three U.S. presidents, will be writing the articles of impeachment.

The critical issues Dr. Lee raises in her lawsuit about the violation of her constitutional First Amendment rights, and the impeachment of the head Family Court judge for her human rights abuses, are of considerable national importance.

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A Disgrace to American Jurisprudence

Darkness Cannot Hide the Corrupt Family ‘Courts’

Far from adjudicating the Law, Family Courts function more like Star Chambers, where the most heinous crimes are committed against the most vulnerable members of society with impunity. Thousands of children and women have died unnecessarily over decades in the “anti-Courts” of Family Court. They are the epitome of judicial abuse par excellence, trafficking innocent lives in a(n at minimum) 50-billion-dollar industry, but no reform is possible as long as they keep Sunlight away from their atrocities. Their genocide-level crimes are hidden through the isolation and decimation of victims, elimination of witnesses, intimidation of reporters, and mayhem and murder — much like in totalitarian regimes such as Saudi Arabia or Russia.

As I started to speak about the horrors I was witnessing, it became clear to me that Family Court abuses are above all a First Amendment problem: they stalked, harassed, and falsely arrested me, while news agencies publishing my interviews were threatened and ordered to take down their articles. Then, they tried to silence me through a phony “protective order,” a bogus contempt finding, and the threat of incarceration. There is a reason why Free Speech is in the very First Amendment of the U.S. Constitution, as the first defense against tyranny. I have therefore filed a federal lawsuit against violators of my Free Speech, as follows:

COMPLAINT

Comes now Plaintiff, BANDY X. LEE, through her undersigned attorneys, and files this Complaint seeking declaratory and injunctive relief and nominal damages against Defendants EVELYN NISSIRIOS and MICHAEL ANTONIEWICZ for flagrant violation of Plaintiff’s right to due process and freedom of speech under color of state law in violation of 42 U.S.C. 1983 and the Fourteenth Amendment. Plaintiff states as follows:

SUBJECT MATTER JURISDICTION

1. This Court possess federal question subject matter over Plaintiff’s claims under 28 U.S.C. 1331 because they arise under federal law, 42 U.S.C. 1983, and the Fourteenth Amendment.

PERSONAL JURISDICTION

2. This Court possesses personal jurisdiction over Defendants because they reside in this District the transactions and occurrences that gave rise to Plaintiff’s claims occurred in this District.

VENUE

3. Venue is proper in this District under 28 U.S.C. 1391 (b) (1) and (2) because Defendants reside in the District and the transactions and occurrences that gave rise to Plaintiff’s claims occurred in this District.

PARTIES

4. Plaintiff Dr. BANDY X. LEE is a forensic and social psychiatrist and a world expert on violence who taught at Yale School of Medicine and Yale Law School for 17 years before joining the Harvard Program in Psychiatry and the Law. Plaintiff resides in New York City.

5. DR. LEE is currently president of the World Mental Health Coalition, the largest professional organization to address the problem of dangerous leadership and its contribution to a “mental health pandemic.’’ During medical school, DR. LEE also obtained a divinity degree to expand her understanding of the human condition and later did a fellowship in social psychiatry. Trained at Yale and Harvard Universities, she was chief resident at Massachusetts General Hospital and a research fellow at the National Institute of Mental Health. At Yale Law School, she taught clinical courses covering the mental health aspects of asylum law, criminal justice, and veteran legal services. Her clinical practice consists of psychiatric services at maximum-security prisons and in state hospitals, in addition to working as an expert witness for criminal and civil courts. At Yale College, she was a popular professor who taught the Global Health Studies course, “Violence: Causes and Cures.” Most recently, with multiple world experts in the field, she helped to co-found the Violence Prevention Institute, which has been commissioned to investigate reforming all forty-four prisons of New York State. Lee served as Director of Research for the Center for the Study of Violence (Harvard, U. Penn., N.Y.U., and Yale), co founded Yale’

6. DR. LEE authored what is considered the most comprehensive textbook on the subject to date, “Violence: An Interdisciplinary Approach to Causes, Consequences, and Cures” (Wiley­ Blackwell, 2019), used in university courses worldwide, published over 100 peer-reviewed articles and chapters, and edited 17 scholarly books and journal special issues. She penned over 300 opinion editorials in outlets such as the Guardian, the New York Times, the Boston Globe, the Independent, and Politico. The World Mental Health Coalition is an educational organization that assembles mental health expe11s to collaborate with other disciplines for the betterment of public mental health and public safety.

7. Defendant EVELYN F. NISSIRIOS is a New Jersey attorney. Defendant Nissirios has been appointed guardian ad /item for Plaintiff’s niece and nephew in Plaintiff’s brother-in-law’s divorce proceedings against Plaintiff’s sister.

8. Defendant Judge MICHAEL ANTONIEWICZ sits on the Superior Court of New Jersey, Chancery Division-Family Part-Bergen County.

INTRODUCTION

9. Family courts are notorious for discounting claims of domestic violence against women and minors in child custody proceedings. The phenomenon has been meticulously documented by the Human Rights Council of the United Nations General Assembly, 53rd session, 19 June-14 July 2023, Agenda item 3, Report of the Special Rapporteur on violence against women and girls, its causes and consequences, 13 April 2023. https://www.ohchr.org/en/specialprocedures/sr-violence-against-women. Among other things, the report noted, “The tendency to dismiss the history of domestic violence and abuse in custody cases extends to cases where mothers and/or children themselves have brought forward credible allegations of physical or sexual abuse. In several countries, family courts have tended to judge such allegations as deliberate efforts by mothers to manipulate their children and to separate themselves from their fathers.”

10. Parties in family court commonly are without knowledge or resources to defend their rights. Transparency thus plays a pivotal role in deterring judicial abuses. It discourages perjury, the misconduct of participants, and decisions based on secret or open bias or partiality. Richmond Newspapers v. Virginia, 448 U.S. 555, 569 (1980). Jeremy Bentham similarly noted, “Without publicity, all other checks are insufficient: in comparison to publicity, all other checks are of small amount.” 1 J. Bentham Rationale of Judicial Evidence 524 (1827).

STATEMENT

11. Plaintiff, Dr. Bandy X. Lee, has written extensively about mental health issues that often arise in Family Court or otherwise.

12. Plaintiff naturally took a keen interest in her sister’s divorce-child custody case in Bergen County, New Jersey. She posted scores of articles about the case alleging bias and unfairness on Medium and Substack often using pejoratives to characterize Co-Defendant Nissirios’ actions as guardian ad litem of her niece and nephew.

13. None of the Plaintiff’s postings disparaging Co-Defendant Nissirios prompted the latter to sue for defamation where truth is a constitutional defense under the First Amendment.

14. Instead, Co-Defendant Nissirios obtained a temporary protective order (TPO) from Co­ Defendant Judge Antoniewicz to evade truth as a defense on December 5, 2024, sub. nom. Evelyn Nissirios v. Bandy Lee, Superior Court of New Jersey, Chancery Division-Family Part, Bergen County, Docket No.: FV-02–74–25. Among other things, the TPO falsely declared, “By consent, Bandy Lee shall remove all posts regarding [Evelyn Nissirios] including any links that Bandy Lee has control over pending further Order of the Court.”

15. Plaintiff Bandy Lee immediately informed the Court that she had not authorized her then attorney to remove her posts regarding Co-Defendant Nissirios; and that she was silenced from raising this objection by the Court clerk who muted her microphone. Plaintiff later submitted an undisputed Declaration repeating that she had never authorized her attorney to consent to removing Plaintiff’s posts. Plaintiff’s former attorney Tricia Lindsay has not disputed Plaintiff’s Declaration.

16. Plaintiff’s posts regarding Co-Defendant Nissirios (four in number) are fully protected by the First Amendment. See e.g., Exhibit 1 (https://medium.com/@bandyxlee/my-proposal-to-a-family-court-judge-jane-gallina-mecca-e3eaf24e3938). No court has ever found any of the postings defamatory or otherwise unlawful. To the extent Co-Defendant Nissirios knew about the postings, it was because she voluntarily chose to visit relevant websites.

17. Notwithstanding the December 5 TPO, Plaintiff did not remove her posts regarding Nissirios because the TRO was flagrantly unconstitutional on at least two grounds: Plaintiff never consented to remove her posts; and, the posts were fully protected by the First Amendment.

18. On January 10, 2025, a hearing was held before Co-Defendant Judge Antoniewicz on Co­ Defendant Nissirios’ motion to hold Plaintiff in contempt for violating the flagrantly unconstitutional TPO in declining to remove her posts relating to Co-Defendant Nissirios.

19. Co-Defendant Judge Antoniewicz held Plaintiff in contempt of the TPO, and ordered Plaintiff to pay $5,381.25 in counsel fees to Co-Defendant Nissirios. Co-Defendant Antoniewicz prohibited Plaintiff from reiterating the twin constitutional defenses she had previously raised against the December 5, 2024, TPO but which Co-Defendant Antoniewicz also refused to entertain at that time: namely, that (1) Plaintiff did not authorize her attorney to consent to the removal of her posts relating to Co-Defendant Nissirios; and, (2) Plaintiff’s posts were protected under the First Amendment.

20. Since the January 10, 2025, hearing and contempt finding, Plaintiff has removed her posts relating to Co-Defendant Nissirios under duress. Plaintiff has been chilled against writing new posts about Co-Defendant Nissirios in violation of the First Amendment for fear of another court finding of contempt and possible jail time. Because of the chilling effect against Plaintiff, transparency in judicial proceedings-especially Family Court — that deters lawlessness, wrongdoing, or misbehavior has been diminished contrary to the public interest in the fair administration of justice.

COUNT I-FREE SPEECH-NISSIRIOS

21. Plaintiff realleges paragraphs 1–20 as if they were alleged anew.

22. Co-Defendant Nissirios acted jointly or in cooperation with Co-Defendant Antoniewicz to issue the TPO on December 5, 2024, unconstitutionally requiring Plaintiff to remove her electronic postings relating to Co-Defendant Nissirios in violation of due process and free speech and to find Plaintiff in contempt of the TPO on January 10, 2025, and impose sanctions in violation of 42 U.S.C. 1983, and the Fourteenth Amendment.

23. The violation of Plaintiff’s free speech contravened clearly established constitutional law as expounded by the United States Supreme Court.

24. Suppression of free speech even provisionally automatically establishes irreparable harm under Elrod v. Burns, 427 U.S. 347, 373 (1976) and its progeny. Everyday Co-Defendant Antoniewicz’s December 5, 2024, TRO remains in effect is a further violation of Plaintiff’s free speech rights. See e.g., New York Times v. United States, 401 U.S. 713 (1971).

COUNT 2-FREE SPEECH-ANTONIEWICZ

25. Plaintiff realleges paragraphs 1–24.

26. Co-Defendant Antoniewicz acted jointly or in cooperation with Co-Defendant Nissirios to issue the TPO on December 5, 2024, unconstitutionally requiring Plaintiff to remove her electronic postings relating to Co-Defendant Nissirios in violation of due process and free speech and to find Plaintiff in contempt of the TPO on January 10, 2025, and impose sanctions in violation of 42 U.S.C. 1983, and the Fourteenth Amendment.

27. The violation of Plaintiff’s free speech contravened clearly established constitutional law as expounded by the United States Supreme Court.

28. Suppression of free speech even provisionally automatically establishes irreparable harm under Elrod v. Burns, 427 U.S. 347,373 (1976) and its progeny. Everyday Co-Defendant Antoniewicz’s December 5, 2024, TRO remains in effect is a further violation of Plaintiff’s free speech rights. See e.g., New York Times v. United States, 401 U.S. 713 (197 l ).

COUNT 3-DUE PROCESS-ANTONIEWICZ

29. Plaintiff realleges paragraphs 1–28.

30. Co-Defendant Antoniewicz prohibited Plaintiff from disavowing her lawyer’s unauthorized consent to remove her postings regarding Co-Defendant Nissirios in issuing its December 5, 2024, TPO against Plaintiff and refused to entertain Plaintiff’s due process and First Amendment challenges to Co-Defendant Nissirios’ January 10, 2025, contempt motion for violating the TPO in violation of 42 U.S.C. 1983 and the Fourteenth Amendment. An unconstitutional court order like an unconstitutional statute cannot serve as the predicate to sanction a violation, a clearly established constitutional rule expounded by the United States Supreme Court.

31. Suppression of free speech even provisionally automatically establishes irreparable harm under Elrod v. Burns, 427 U.S. 347,373 (1976) and its progeny. Everyday Co-Defendant Antoniewicz’s December 5, 2024, TRO remains in effect is a further violation of Plaintiff’s free speech rights. See e.g., New York Times v. United States, 401 U.S. 713 (1971).

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests this Court to grant the following relief:

(a) Enter judgment for Plaintiff on Counts 1, 2, and 3;

(b) Declare the December 5, 2024 TPO directing Plaintiff to remove her online posts relating to Co-Defendant Nissirios unconstitutional and enjoin Co-Defendant Antoniewicz from enforcing the TPO, including invalidation of the January 10, 2025, sanction imposed on Plaintiff for violating the unconstitutional order.

© Award nominal damages against Co-Defendant Nissirios and Co-Defendant Antoniewicz;

(d) Award attorney’s fees under the Civil Rights Attorney’s Fees Award Act of 1976, 42 U.S.C. 1988; and,

(e) Such other relief as this Court finds just and proper in the circumstances.

Respectfully submitted,

ls/Bruce Fein

Bruce Fein

Law Offices of Bruce Fein

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