Free Speech Violation Disguised as a Protective Order

My Affidavit Reveals the Lengths to which Family Court Actors will Go to Hide Their Violent Crimes and ‘DARVO’ (Deny, Attack, and Reverse Victim and Offender)

AFFIDAVIT OF BANDY LEE

I, Bandy Lee, duly sworn upon oath, declare the following statement is true to the best of my knowledge:

1. I am a forensic psychiatrist and expert witness for the courts with twenty-five years of experience. I am also a faculty member of the Harvard Program in Psychiatry and the Law. When I consulted a preeminent constitutional scholar at Harvard Law School with all the evidence I had, he agreed that [Guardian ad Litem, or hitherto “GAL”] and the court of Jane Gallina-Mecca were violating the U.S. Constitution. He even wrote a personal letter to Judge Gallina-Mecca, urging her to make a correction, but she did not, and now she is under federal litigation, along with [GAL].

2. In January 2022, shocked at [GAL’s] and Jane Gallina-Mecca’s lack of due process and contempt for the law, to engage in extreme human rights violations, I informed them that, unless they corrected course, I would go public with their deeds. They merely responded that I am “not a litigant,” and conveyed no concern. Indeed, I would come to discover routine, reckless endangerment of lives under Gallina-Mecca, with at least one death widely publicized. [GAL] herself has boasted “absolute judicial immunity” regarding her deeds.

3. I have worked for the past two and a half years to expose [GAL] as a corrupt court official who endangers the lives of the very children she has been entrusted to protect. Without remorse, she has harassed, falsely arrested, orchestrated false police raids, and co-conspired to intimidate witnesses — and has invariably given custody to physically or sexually abusive parent in virtually all of the cases in which she has participated.

4. The main question is: How is telling the truth harassment? [GAL’s] petition is nothing but a naked attempt to circumvent the First Amendment, through semantical obfuscation, and the rebuke she received from the legal departments of major magazines and news outlets. She and Jane Gallina-Mecca were reprimanded for their “presumptively unconstitutional prior restraint against ongoing publication.” An article in the Washington Post reported Gallina-Mecca’s illegal interference with the press in the past. [GAL’s] goal is clear: to bend the law backwards to try to make my constitutionally-protected speech a threat of physical violence, so that she can continue preying on vulnerable children with impunity.

5. In her certification, [GAL] lies or misleads many times. Most notably, she concocts a connection between me and a third author who advocates the Second Amendment, displays stacks of ammunition, and places her picture between crosshairs. Her dramatic display belies the fact that she already knows there is absolutely no connection between me and this author: when that article was published, she immediately called the state police. After a thorough investigation, the state police concluded that there was no basis whatsoever for her making a connection. At the time, she assumed that I wrote the article. My first article on [GAL], dated February 17, 2023, clearly postdates that article, as I cite the article and denounce any violence (see Exhibit A).

6. [GAL] has refused to accept that multiple agencies and individuals are investigating her and Gallina-Mecca’s crimes, as the above author demonstrates. Instead, she has harassed and intimidated me and my sister for any random information that got out on her case. She used this false attribution to sanction my sister with almost $27,000, when the judge recommended $5000 ([GAL] said that the only way she would accept $5000 is if my sister would stop any future articles from being published — a power my sister clearly did not have). The absurdity of [GAL] taking out a protective order against my sister, when my sister has not posted or said anything negative about [GAL] — her last communication was an email related to her litigation, dated July 23, 2023 — reveals the total lack of any semblance of credibility of these bogus charges.

7. Lest we forget — my sister had her screaming, crying children literally pulled from her arms by a “SWAT team” of five police officers, in a blatant kidnap that was fully orchestrated by [GAL] and her abusive husband. This occurred after [GAL] specifically gave her custody time with her children that weekend, at which time they went to a nearby hotel to access the pool, because they were suicidal after being secretly taken to a faraway resort by their father the weekend before (upon which the children called their maternal grandfather in terror — which was how we found out that the abusive father violated court directives to take them out of state without permission).

8. Instead of protecting these children, [GAL] has not only allowed their abusive father to abduct and isolate them but has harassed, intimidated, assaulted by false police raid, and almost caused the death of the mother. The mother developed post-traumatic stress disorder (PTSD) only after [GAL’s] raids, when she had not acquired this diagnosis even after suffering thirteen years of domestic violence and coercive control. [GAL] is solely responsible for abducting her previously healthy and happy children from their primary caregiver and devoted mother to isolate them with their abusive father — who almost killed each of them by head injury and was placed on a restraining order shortly before [GAL] transferred them to his sole custody, to their extreme medical decline ever since.

9. Additionally, [GAL’s] violation of my First Amendment rights through a false claim of “threat” constitutes a curtailment of my rights and privileges as a physician. I am a mandated reporter, legally required to report child abuse at any medical suspicion, and to repeatedly report it if the abuse is ongoing. I have encountered obstacles every step of the way because of her and Jane Gallina-Mecca’s interferences with Child Protective Services and the Child Abuse Hotline. Therefore, I am acting on my conscience when I am speaking for the scores of children [GAL] has victimized, all to their verifiable decline.

10. [GAL’s] greatest fear is that the truth will be revealed. She conjures up an implausible false narrative that she is being physically threatened by randomly picking a “tweet” from someone whom I have never met nor contacted. I am a New York Times bestselling author and a public intellectual with an X audience of over 100,000. Of the thousands of posts I make per year, if one erratic response to my articles was all [GAL] could find, then it is only proof that the benefit and protection of life I try to provide far outweigh any unintended harm. Since my articles, judicial reformers have called upon me to testify before seven different State legislatures to help protect children from Family Court abuses. Almost forty other victim litigants of [GAL] have come forward and shared their stories with me, which has familiarized me with [GAL’s] decade-long pattern of transferring thriving children from devoted parents and nurturing homes to hand them to abusers (usually, an abusive father who is paying her to steal the children, whom he would then use to extort “child support” or other, sometimes extreme, money-making schemes). A documentary film is underway with their testimonies.

11. When the Saddle River community, which was protesting her remaining on their Board of Education despite their voting her out (she was voted out in November 2023), invited me to report to the Board my observations, several of the above victim parents offered to testify. We were in the process of arranging these testimonies before the Board when [GAL] filed her protective order.

12. The one who needs a protective order against her is [GAL], not myself or my innocent sister. [GAL] has constantly harassed my sister for my articles, when my sister has never been my source of information and never has prior knowledge of any of my publications. I write about what I have witnessed myself, what independent investigators have told me, and what I read about in articles such as the one [GAL] cited, which often have more information on my sister’s case than I myself knew. Many who are familiar with [GAL’s] and Gallina-Mecca’s gangster-like methods have warned me about my own physical safety. I took down several articles in response to their cautioning that my life could be in danger, and others have told me, in no uncertain terms, that my public presence and free speech were keeping me alive. There is at least one reporter who died while confronting Gallina-Mecca, and [GAL] is known for her violent police raids, which she even perpetrated on the Saddle River community, much to their shock (it had never in its history experienced such violence by a Board of Education member against a parent). One violent raid almost killed my sister, for which the State of New Jersey criminally charged [GAL] as of March 26, 2024 (see Exhibit B). [GAL] lied in her certification that no criminal charges exist. Because of an error in a recent probable cause hearing (where the judge did not hear the amended charges), these charges are being resubmitted. [GAL’s] lies to the police have been submitted to the Bergen County prosecutor, in addition to her more than 350 lies to the court and multiple counts of felony perjury, just in my sister’s case. The rest is being litigated in federal court, including her and Gallina-Mecca’s violations of my First Amendment rights.

13. This is not a protective order against a “threat”. This consists of a “cease and desist” order from publishing or speaking the truth, in a desperate attempt by [GAL], under the tacit approval of Jane Gallina-Mecca, to silence me and my sister so as to deny our First Amendment rights of freedom of expression. They are falsely claiming the need for a protective order to suppress our rightful criticism of their extreme abuses of judicial authority, by which my sister’s two children were illegally and unconstitutionally abducted from her without due process; to negate our federal charges; and to undermine the petition for impeachment against Gallina-Mecca that over thirty of her victim litigants organized, which has gathered almost 600 signatures in just three weeks. This is also why they are using a fellow judge in the Bergen County Family Court system under Gallina-Mecca’s supervision as chief judge, to silence me in my writing and expression — thereby preventing me from bringing their illegal and unconstitutional abuses of authority under public scrutiny. For all these reasons, the protective order against me and my sister should be dropped.

Signed and Notarized,

Bandy X. Lee, M.D., M.Div.

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