Probable Cause Found!

Bandy X. Lee
6 min readNov 7, 2024

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… Against One of the Accomplices of a Corrupt Family Court Guardian ad Litem (Those who Know Family Court Know How Difficult This is!)

Family Courts could not carry out their organized crime of trafficking children to their abusers, fixing “evidence”, silencing witnesses, and destroying victims’ ability to fight back or to speak up, if not for accomplices. These may include police officers, school officials, and even health professionals. After a series of setbacks, including established criminal charges against the guardian ad litem mysteriously being reversed, probable cause was finally found against a pediatrician who altered her medical records, tampered with evidence, and intimidated witnesses, so that the abuser of children could get away with kidnapping and concealment of children. There is little doubt that she did this under the corrupt guardian ad litem’s direction or “guarantee” of immunity — but she forgot that those outside of Family Court do not always see things the same way. The judge presiding over this case was extremely professional and refreshingly straightforward — and granted probable cause right away, without any of the funny business, deflections, distortions, and perversions so common in Family Court! Below is my affidavit:

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, former fellow of the National Institute of Mental Health (NIMH), and consultant of the World Health Organization (WHO), who taught at Yale School of Medicine and Yale Law School for seventeen years before joining the Harvard Program in Psychiatry and the Law. In 2002, I assisted in the WHO’s launch of its World Report on Violence and Health. In 2007, I coauthored the United Nations Secretary-General’s chapter on “Violence against Children.” In 2013, I submitted a report on Rikers Island Correctional Facility that brought in federal investigators and initiated reforms. I helped the French Ministry of Justice reform its criminal justice system in ways that are now emulated around the globe. I have now been asked to help reform New York State’s entire system of 44 prisons, simultaneously to reduce violence and solitary confinement, which I have already demonstrated with the San Francisco County Jails. I have been an expert witness in over 200 criminal and civil court cases, of which approximately 40 were family court cases. I have authored over 100 scientific articles, over 300 opinion editorials, and an authoritative textbook, Violence. I have witnessed and documented the actions of Dr. K.W., as the pediatrician of my niece and nephew, X and Y.

2. Dr. W. was the first physician (among approximately a dozen health professionals) to acknowledge to the mother, Patricia Lee, that their father, Alan T. Chan, was physically and psychologically abusive and neglectful to them, which led to their acts of self-harm, suicide notes, and one witnessed suicide attempt. I witnessed all of this in real time, as well as am the firsthand witness of Mr. Chan’s daily violent abuse of his children and spouse.

3. On September 29, 2021, as part of my legally-mandated reporting of child abuse and endangerment, I sent Dr. W. a copy of Mr. Chan’s alarming psychiatric diagnosis — psychopathy — as simultaneously but independently diagnosed by myself and Dr. Michael Stone, one of the nation’s top experts on psychopathic disorders.

4. Instead of heeding our warnings, Dr. W. violated HIPAA (medical confidentiality) laws to give the report to Mr. Chan, which endangered his victims, who gave their reports under promise of anonymity (the diagnosis of psychopathy relies on the multiple interviews with victims as collateral sources).

5. Dr. W.’s failure to make a mandated report, but rather pretending that the children were “fine” led to Mr. Chan’s ability to kidnap and conceal the children, since November 12, 2021. For example, she omitted the children’s missing half of school, suffering injuries that an orthopedist said were “neglected for months,” making multiple emergency room visits, undergoing surgery from dental neglect, being recklessly exposed to Covid-19 and Hepatitis B, etc., since their violent transfer to the father’s “care” three years ago. Mr. Chan, meanwhile, prevented anyone other than Dr. W. from examining them. At the same time, Dr. W. removed documentary evidence she previously included on the children’s abuse from the medical records.

6. Yet, Dr. W.’s records themselves showed that they went from average height and weight to the bottom of their age groups, but she did not find this alarming at all. Instead, she falsified her records to leave out orthopedic injuries, emergency room visits, and their missing almost half of school since the forced abduction.

7. On August 3, 2023, Patricia Lee called to request her children’s annual checkup records and was told that she could pick them up on the next day, August 4, 2023. When she did, the most critical notes were missing from the records. Failing to resolve the issue by phone, Patricia Lee presented to Dr. W.’s office, and after great effort received the records but found out that the content was tampered with, and the growth charts — which showed extreme failure to thrive in the past — were missing. Rather, Dr. W.’s notes contained critical falsehoods, fabrications, and serious omissions, in order to paint a fraudulent, “rosy” picture. Patricia Lee asked to meet with Dr. W. but was told that there was a new “rule”: the pediatrician could not see a parent without her children! Upon hearing this, I decided to try to speak to her as physician to physician and went to Dr. W.’s office directly from work. Instead of meeting with a colleague as a normal professional would, Dr. W. refused to appear. When I showed my physician badge and stated that this regarded a medical emergency and child endangerment, the office staff astonishingly began to call the police!

2C:28–5 Tampering with witnesses and informants; retaliation against them.

Dr. W., believing that an official proceeding or investigation is pending or about to be instituted or has been instituted, knowingly engaged in conduct that a reasonable person would believe would cause a witness or informant to:

(2) Withhold documents;

(3) Elude legal process summoning them to testify or supply evidence;

(5) Otherwise obstruct, prevent, and impede an official proceeding or investigation into Alan T. Chan’s child abuse.

b. Retaliation against witness or informant. Dr. W. attempted to harm both Patricia Lee and myself, both reporters of Alan T. Chan’s child abuse and one a fellow physician, with purpose to retaliate for or on account of the service of Alan T. Chan, through threat of arrest.

N.J.S.A. 2C:33–2, Disorderly Conduct, by failure to report child abuse

According to Title 9:6–8.10, any person having reasonable cause to believe that a child has been subjected to child abuse, including sexual abuse, or acts of child abuse shall report the same immediately to the Division of Child Protection and Permanency by telephone or otherwise. Dr. W. failed to do so when she herself agreed that these children were being abused and related this to the mother, Patricia Lee, recommended a child psychiatrist for this reason, and accepted and inserted documentary evidence into the medical record. She not only failed to report the abuse as a mandated reporter but later colluded with the abuser, Alan T. Chan, to cover up his abuse and support his kidnapping and concealing them for three years. Because of her actions, a substance-abusing, pornography-addicted, and violent, previously absentee father, who was formerly on a restraining order for almost killing each of his children by head injury, was allowed to kidnap and conceal his children in order to gain financial advantage in his divorce (based on his “warehousing” the children, he is demanding six-figure “child support,” the house, all his legal fees, and refusing to pay any alimony, despite making a million dollars a year). Without Dr. W.’s support and medical “rubber stamping” of his violence, he would not have been able to achieve any of this.

Signed, Bandy X. Lee, M.D., M.Div., and Notarized on the 13th day of July, 2024.

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Bandy X. Lee
Bandy X. Lee

Written by Bandy X. Lee

Forensic psychiatrist, violence expert, president of the World Mental Health Coalition (worldmhc.org), and New York Times bestselling author.

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