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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