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 henceforth “GAL”] and the court of Jane Gallina-Mecca were violating the U.S. Constitution. He even wrote a personal letter to Gallina-Mecca, urging her to keep with the Constitution, but she ignored it.
2. In January 2022, alarmed at [GAL’s] and Jane Gallina-Mecca’s due process violations and contempt for the Law in my sister’s [henceforth “Mother’s”] case, I informed them that, unless there was a change of 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 invariably gave custody to the physically or sexually abusive parent in virtually all cases in which she participated.
4. [GAL] is now abusing a new statute that allows for a protective order against “cyber harassment” and “stalking”. How is telling the truth harassment? Her petition is a naked attempt to circumvent the First Amendment, and a rebuke she received from legal departments of major news outlets, for her and Gallina-Mecca’s “presumptively unconstitutional prior restraint against ongoing publication.” The Washington Post previously reported on Gallina-Mecca’s illegal interference with the press. [GAL’s] goal is clear: to bend the law backwards to make my constitutionally-protected speech a threat of physical harm, so that she can prey on vulnerable children with impunity.
5. [GAL] lies or misleads multiple times in her certification. Most notably, she concocts a connection between me and a third author, unknown to me, who advocates the Second Amendment, displays stacks of ammunition, and places her picture behind crosshairs. Her dramatic display belies the fact that she already knows there is absolutely no connection between me and this author, because when this article was first published on February 4, 2023, [GAL] immediately called the state police. The state police did a thorough investigation and concluded that there was no basis whatsoever for her making a connection with me. At the time, she assumed that I wrote the article. My very 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 acknowledge that multiple agencies and individuals are investigating her and Jane Gallina-Mecca’s crimes, as the above-referenced article makes clear. Instead, she has harassed [Mother] for any random party that revealed about her case. She even used this false attribution to force [Mother] to pay almost $27,000, without an investigation, when the judge recommended $5000 ([GAL] stated that the only way she would accept $5000 is if [Mother] would stop any future articles from being published — a power [Mother] clearly did not have). The absurdity of [GAL’s] taking out a protective order against [Mother], when [Mother] has never posted or said anything negative about [GAL] — her last communication was an email related to her litigation, dated July 23, 2023 — reveals [GAL’s] total lack of credibility.
7. Lest we forget — [Mother] had her screaming, crying children literally pulled from her arms by a “SWAT team” of five police officers, in a blatant kidnap orchestrated by [GAL] and her abusive husband. [GAL] assigned her to be with her children that weekend, when they went to a nearby hotel to access a pool, as the children were suicidal after their father had secretly taken them to a faraway resort the weekend before (they called their maternal grandfather in terror — which is how we learned that he violated court directives by taking them out of state without permission).
8. Instead of protecting these children, [GAL] has not only co-conspired with their abusive father to abduct and isolate them but has harassed, intimidated, assaulted by false police raid, and almost caused the death of [Mother]. [Mother] developed post-traumatic stress disorder (PTSD) only after [GAL’s] raids, when she did not have this diagnosis even after thirteen years of domestic violence and coercive control. [GAL] is solely responsible for abducting her previously healthy and happy children from their devoted mother to isolate them with the 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 precipitous medical decline ever since.
9. Additionally, [GAL’s] request for a gag order 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 ongoing abuse. 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. Gallina-Mecca has also shielded [GAL] from investigation by the Office of Attorney Ethics.
10. [GAL’s] greatest fear is exposure of the truth. She has conjured up an implausible false narrative that she is being physically threatened because of a “tweet” from someone whom I have never met nor contacted. I am a New York Times bestselling author with an X audience of over 100,000. Of my thousands of posts, if one erratic response was all [GAL] could find, then the protection of life I endeavor to provide clearly outweighs any unintended harm. Since my articles, judicial reformers have called upon me to testify before seven different State legislatures about Family Court abuses. Almost forty other victim litigants of [GAL] have come forth to share with me [GAL’s] pattern of transferring thriving children from devoted, nurturing parents to abusers (who use the children to extort “child support” or for other money-making schemes). A documentary film is underway with their testimonies.
11. What [GAL] is calling “stalking” is the fact that the Saddle River community, protesting her remaining on their Board of Education — despite her being voted out in November 2023 — invited me to report my observations to the Board. Several of the above victim parents offered to testify, which we were in the process of arranging when [GAL] filed for her abusively frivolous protective order.
12. The irony is that the one who needs restraining is [GAL], not myself or [Mother]. [GAL] has constantly harassed [Mother] for my articles, when [Mother] has never been my source of information. I write about my own witness, what independent investigators tell me, and what I read about in articles such as the one [GAL] cited, which often have more information on [Mother’s] case than myself. Additionally, [GAL] has violently assaulted or arrested both of us through false police raids by lying to the police, after which all charges were dropped. One violent raid almost killed [Mother], for which the State of New Jersey criminally charged [GAL] as of March 26, 2024 (see Exhibit B). She even perpetrated a violent police raid against a parent of the Saddle River community — which shocked a community unaccustomed to such violence by a Board of Education member in its history. Many who are familiar with [GAL’s] and Jane Gallina-Mecca’s gangster-like ways have warned me that my life is in danger. I have taken down several articles in response to their cautioning, and others have told me, in no uncertain terms, that my public presence was keeping me alive. There is at least one reporter who died while confronting Gallina-Mecca. [GAL] gets her way through weaponization of the police, threats, intimidation, and constant lying. She lied in her certification that no criminal charges exist. Her more than 350 lies to the court and multiple counts of felony perjury have been submitted to authorities. The rest is being handled through federal litigation.
13. This protective order is therefore a subterfuge for an illegal “cease and desist” order from my publishing or speaking the truth. [GAL’s] desperate strategy, under Jane Gallina-Mecca’s tacit approval, is to deny my First Amendment rights of freedom of expression. Bringing under public scrutiny their abuses of power, in government betrayal of public trust, is the very purpose of the First Amendment. By claiming a false “threat of harm,” they intend to hide their public harm; to negate our federal charges; and to undermine the petition for Gallina-Mecca’s impeachment that over thirty of her victim litigants have organized, gathering 700 signatures in three weeks. This is why they are using a fellow judge in the Bergen County Family Court system under Gallina-Mecca’s supervision as chief judge, to silence my free expression. Both [GAL] and Gallina-Mecca have a track record of trying to exert control over me, first by pulling me into [Mother’s] divorce case (even as they denied me my testimony), and now through a frivolous protective order, which is but a perversion to restrain victims’ ability to challenge perpetrators. Their obvious intent is to stigmatize me, to justify future assaults against me, and ultimately to endanger my life. Before moving forward, there must be an unsealing of [Mother’s] court records, which should reveal that the seal itself, secretly issued and backdated by four months (for which we have proof), was not to protect children but to cover up [GAL’s] and Gallina-Mecca’s egregious, predatory exploitation of them and the adults who love them.
Signed and Notarized,
Bandy X. Lee, M.D., M.Div.
