Dean Tong has been a media commentator for the following high profile cases: Bridget Marks (Dean Tong's Affidavit that has been introduced on the record in the Marks case).

Affidavit of Dean Tong

Before me, the undersigned authority, on this day personally appeared Dean Tong, known to me to be the person whose name is subscribed to the following instrument and having been duly sworn, upon his oath, deposes and states:

I. I have prepared this Affidavit at the request of the Respondent, Bridget Marks, her fiancee, and the Respondent’s counsel.

II. I hold a B.S in Biology with a minor in Psychology from Boston’s Northeastern University and am a Masters of Science in Child Forensic Studies Candidate at the Universities of Portsmouth and Leeds in England.

III. I am self-employed as a Forensic Trial Consultant specializing in high-conflict and contested child custody and abuse cases, including Parental Alienation, nationally. I’ve consulted on tens of thousands of alleged molestation cases over the past 20 years and have been retained to consult on hundreds of cases by parents and attorneys from 41 states. I’ve published three self-help books – Elusive Innocence (Huntington House, 2002), ASHES to ASHES…Families to Dust (FamRights Press, 1996), and Don’t Blame ME, Daddy (Hampton Roads, 1992), all addressing unfounded and false child sexual abuse accusations. I’ve given presentations relative to child sexual abuse accusations, pedophilia, cognitive child development and child suggestibility in 15 states and in Toronto and Saskatchewan, Canada. I’ve testified as an expert witness in W. Virginia and Iowa.

IV. I have been asked by the Respondent’s fiancee to review and critique Dr. Stephen Bates Billick’s Curriculum Vitae. In addition, I’ve reviewed the Decision and Order from Judge Arlene Goldberg in Docket No.: V-01744-5/03 dated May 20, 2004; the Decision and Order On Custody from Judge Arlene Goldberg in Docket No.: V-01744-5/03 dated May 21, 2004; Notice of Motion for Stay Pending Appeal in Docket No.: V-01744/03 dated May 26, 2003; Affidavit in Support of Respondent’s Application for a Stay in Docket No.: V-01744/03 dated May 26, 2004; Verified Complaint filed by Respondent’s Attorney Thomas Shanahan on behalf of Bridget Marks in United States District Court, Southern District of New York, dated May 31, 2004; the existing case law as it pertains to the Marks case, and various media articles relative to the Marks case.

V. I have not met the litigants or the children and have not been retained by Bridget Marks or her counsel, and have not received any monies in the case-at-bar.

VI. Parental Alienation, as defined by Douglas Darnall, Ph.D. in his book “Divorce Casualties,” does not consider the same a diagnosis as it’s not described in the DSM-IV or DSM-IV-TR. Dr. Darnall does consider Parental Alienation to be a phenomenon that describes a very specific interaction between children and their parents.

VII. Nowhere in Dr. Billick’s Curriculum Vitae does it allude to the fact that he is published in Parental Alienation, or has lectured relative to Parental Alienation.

VIII. The case law in New York is clear, referencing In The Matter of Karen B. v. Clyde M, 197 A.D.2d 753 [3d Dept 1993] 602 N.Y.S. 2d 709, that the New York courts recognize Parental Alienation in contentious child custody cases, but not Parental Alienation Syndrome, as the latter has not passed the Frye Test as being generally accepted science throughout the psychological community. Nowhere in Dr. Billick’s Curriculum Vitae does it allude to the fact that he’s published in sexual deviancy issues, or has lectured relative to sexual deviancy issues, in specific, the PPG (Penile Plethysmograph). The PPG is the most objective and direct measurement of a man’s sexual arousal or interest to children, which would indicate whether or not said man would possess the propensity to be a pedophile (Predicting Relapse: A meta-Analysis of Sexual Offender Recidivism Studies.

R. Karl Hanson and Monique T. Bussiere, Department of the Solicitor General of Canada. In: Journal of Consulting and Clinical Psychology, edited by the American Psychological Association, 1998, Vol. 66, No. 2, pp 348-362

IX. Dr. Billick never queried the Association for the Treatment of Sexual Abusers (www.atsa.com) to glean whether or not they recommend the Petitioner submit to a PPG, and other psychosexual tests prior to the release of his findings and final report to the court.

X. While the undersigned publishes in Chapter 8, The SAID (Sexual Allegations In Divorce) Syndrome, of his book Elusive Innocence, the fact that the timing of a child sexual abuse accusation made within an acrimonious child custody battle is a “red flag,” it doesn’t necessarily mean it’s a false or unfounded accusation.

XI. Nowhere in Dr. Billick’s Curriculum Vitae is it memorialized that he has conducted numerous forensic child interviews within alleged incest cases, or has published empirically-based peer-reviewed studies and articles relative to cognitive or structured forensic child interviews. Nowhere in Dr. Billick’s CV is it memorialized that Dr. Billick has studied or lectured relative to the work of Stephen Ceci, Ph.D., Maggie Bruck, Ph.D., Stephen Lindsey, Ph.D., Debbie Poole, Ph.D., Michael Lamb, Ph.D., Phillip Esplin, Ed.D., Karen Saywitz, Ph.D., and Anne Graffam Walker, Ph.D., all of whom are experts in the field of cognitive child development, young children’s suggestibilities, memory contamination, and linguistic errors.

XII. Nowhere is it acknowledged by the court that Dr. Billick conducted (using Statement Validity Analysis protocol as required by the National Institute for Child Health and Human Development from Bethesda, MD) structured or cognitive forensic child interviews with Amber and Scarlett Marks via video and/or 1-way/2-way mirror. It was learned by the undersigned that the only forensic interview technique employed by Dr. Billick with the children was that of anatomical drawings, a type of play therapy. Play therapies are not a proper interviewing protocol to be used in diagnosing child sexual abuse. Furthermore, nowhere is it acknowledged by the court that the two certified social workers or appointed Law Guardian conducted structured or cognitive forensic child interviews with the two children. Furthermore, nowhere is it acknowledged on the record seen by the undersigned, that the Court conducted, sua sponte, a Frye or Taint Hearing with a qualified suggestibility expert or experts, for the purpose of determining whether or not the children’s disclosures of sexual abuse by their father were made contemporaneously so and contained an indicia of reliability and an inherent degree of trustworthiness.

XIII. There is a huge body of scientific evidence to support the work of structured forensic child interviews as the gold standard protocol to be used: Lamb, M. E., Sternberg, K. J., Esplin, P. W., Hershkowitz, I., & Orbach, Y. (1997). Assessing the credibility of children's allegations of sexual abuse: Insights from recent research. Learning and Individual Differences, 9, 175-194. Lamb, M. E., Sternberg, K. J., Esplin, P. W., Hershkowitz, I., Orbach, Y., & Hovav, M. (1997). Criterion-based content analysis: A field validation study. Child Abuse and Neglect, 21, 255-264. In fact, an excellent website that publishes proper forensic child interview techniques and protocols is located at www.law.duke.edu/journals/lcp/articles/lcp65dWinter2002p149.htm

XIV. In light of the foregoing, I recommend that the Court order an independent and qualified child developmental psychologist and suggestibility expert interview Amber and Scarlett Marks via video and/or 1-way/2-way mirror. In addition, if the Respondent is willing to pay the expense of the testing, the court should consider entertaining an order to compel the petitioner to undergo psychosexual testing by an expert published in sexual deviancy issues. Said testing should include a Penile Plethysmograph and Abel Screen (www.abelscreen.com).

Further Your Affiant Saith Not,
Executed this _______ day of July, 2004 in Riverview, Florida

Dean Tong
10246 Hunters Haven Boulevard
Riverview, FL 33569
813.657.4930, Ph/Fax
www.abuse-excuse.com

Subscribed and sworn to before me by Dean Tong on this ________ day of July, 2004 to certify which witness my hand and seal of office.

_______________________________________
Notary Public