e2/24/2M14 93:34 8136574930 DEAN TONG PAGE O1 / Page | of 3 Dean Tong, MSc. February 24, 2014 To: Tony Rackauckas, District Attorney of Orange County, California Copy: Al Stokkey, Esq. Criminal Defense Attorney for Mahatep Srikureja, Matthew De Armey, Esq. Family Law Attorney for Mahatep Snkureja, ; Judge Glenn Salter, Superior Count of Orange County, Orange, California, Lamoreaux Justice Center, 347 The City Drive, Family Law Department | -60, john Cate, Esq, Minors Counsel; Ron Funk, Esq., Arnold Porter Law Firm, ‘Washington, D.C., and Margot Speyer, Esq. Re: Retraction of Prior E-Mail Report of Dean Tong dated ist 31, 2013 Alexandria "Lexi" Dillon-Srikureja, DOB 10-17-2004, Case No. 05P000379 and Case No. 30-2013-00693024-PR-GP-CJC Dear District Attorney, Mr. Rackauckas. The purpose of this letter is to retract my report sent to you on or about August 21, 2013. The report was provided to Al Stokkey, Esq., Father's criminal defense attorney, for the purpose of Father's criminal defense. The retraction is necessary as | have recently been informed and | now believe that | was misled and deceived by Father and his defense team. My report therefore contains erroneous conclusions, as the conclusions were based on false and misleading information. On June 3, 2013, | was retained by Matthew Srikureja, the father uf ‘Alexiandra "Lexi" Dillon-Srikureja, born October 17, 2004. At the time he retained me, Matthew Srikureja had been alleged to have sexually abused Lexi and was under criminal invostigation for the same. Matthew denied all allegations, and counter-alleged that Ruby Biton. the mother, was making false allogations for purposes of obtaining custody. As requested by Father, | bagan to investigate the circumstances of the allegations. ‘As part of my normal investigation in any case, and as part of the invostigation in ths case, 1 fequested Father provide me with a copy of the case file. | knew there had beon CAST (on rtews, and 801 also asked Father's defense team and Father to arrange an opportunity for me to review the CAST interview tapes (there were four separate interviews, according to Father) Despite my repeated requests made to Mr. Srikureja and his defense atlomey®, 1 rae ver provided with this information nor was | able to review the CAST DVDs: |also requested from Father, the discovery from the court-appointed therapist for Lex) What Father provided me with was the work product from therapist Grace Coleman, whom Father represented to me, had been appointed by the court to provide therapy to Lexi. This was false and Father knew It to be false when he provided me Grace Coleman's work product, fend passed i off as "he court appointed therapists" fle. Father had, without permission from the court, began to send Lexi to Grace Coleman for therapy. Grace Coleman's opinion was that Matthew Srikureja did not abuse Lexi, Grace Coleman had never worked with any child Monday, February 24, 2014 AOL: DeanTongPAGE 02 Page 2 of 3 02/24/2014 09:34 8136574930 DEAN TONG previously; Lexi was her first child client. Therapy was didactic, and not individual, thus of limited value to any objective investigator. To be very clear, Grace Coleman is not and never had been at any time the court appointed therapist for the child, and Matthew Srikureja knew this and intentionally misrepresented this material fact to me. As a result of Grace Coleman's knowing participation in this deception, Grace Coleman is being investigated by her governing board. Atall times relevant, Thea Reinhart. Ph.D., was the court appointed therapist for Lexi. Father never provided me with Dr. Reinhart's Curriculum Vitae (CV), or clinical session progress notes. Dr. Reinhart had come to a different conclusion about the veracity of Lexi's disclosures, and had, as | later learned, in her professional opinion based on her thirty-five (35) years of experience with children, determined Lexi was telling the truth. Thea Reinhart, Ph.D. is an experienced, respected clinical therapist. For the past thirty-five (35) years, she has been a panel therapist and has received numerous appointments to provide court- ordered therapy to children. In this time, Dr. Reinhart has never had any complaints or investigations into her work and/or ethics. Her opinion should be considered in reaching any determination about the matter of Matthew Srikureja and Ruby Dillon. In late August, just as they pressed me for an advisory opinion about the allegations, Father's defense team did finally provide me with roughly 300 pages of discovery. | issued the report after reviewing only this material, which | believed was all material available. It is fair to say that | was shocked to learn in January 2014, that the court file / discovery consists of at least 3300 pages. It was at this time | realized the enormity of the situation: Father and his defense team "cherry picked” documents that favored him and made Ruby Dillon look bad; Father and his team literally "created" a secand "court-appointed therapist” when the real court-appointed therapist's views did not support Father's position, and Father Purposefully omitted material relevant facts. The materials presented to me were specifically ‘ochestrated to denigrate and discredit Dr. Reinhart for the purpose of discrediting the allegations of sexual abuse, so that Father's criminal case might be dropped. In fact, this was, the result that Father obtained after procuring my report through intentional misrepresentation of material fact. Father Matthew Srikureja refused to heed my professional advice to clear his name through a risk assessment / psychosexual battery of tests to include the AASI-3. Had he done so, and passed the test, this would have tended to make it less likely that the allegations of sexual abuse were true. | provided Father every opportunity to submit to this testing but he never complied with my request. Finally, | remain very concerned that | was never provided an opportunity to review the four (4) CAST interviews that Lexi underwent. | understand the interviews are on DVD. These interviews would provide an expert like me significant insight into the allegations. Combined with my education and training, | have made a career and a nationally-known and respected name for myself because of my experience and specialized knowledge in the area of forensic child abuse investigation. | believe that Father and his defense team purposely and intentionally failed to provide these DVDs for my review because they are afraid of what the interviews reveal about Matthew Srikureja and the allegations of abuse. | cannot be sure, of course, and | would welcome an opportunity to review the DVD, in any capacity your agency deemed appropriate. In sum, as a result ofthe biatant and bold, intentional misrepresentation of material fact and fraud that the Father and hig upon me, your agency, and the court, the conclusions | reached ty ier on oe rae Free rocarrect, in particular, | want to apologize for erroneous assertions | madeabout Dr ney are untrue and were the result of meticulous manipulation of fact by Monday, February 24, 2014 AOL: DeanToag02/24/2014 99:34 8136574930 DEAN TONG Pace 03 Page 3 of 3 Father and his defense team. In light of these new facts, | retract the August 2013 report | provided to Al Stokkey, Esq., Matt DeArmey, Esq. and your office. | respectfully urge that your agency re-open any and all allegations that were pending against Father, which were mitigated or dropped as a result of my report. These allegations should be reopened and reconsidered in full. Additional allegations against Father and his defense team, and Grace Coleman, for deliberately providing false information as if it were true, are appropriate in light of the intentional deception intended to perpetrate a fraud upon the courts and judicial system If can be of any assistance please contact me at 813-417-5362. | regret any confusion and delay in investigation | may have caused. | Remain. Yours Respectfully, oe (Cam (org Dean Tong Dean Tong, MSc., Forensic Trial Expert 604 Brentwood Place Brandon, FL 33511 813.657 4930, Office/Fax 813.417.5362, Mobile http /www_abuse-excuse.com http:/en wikipedia ,org/wiki/Dean_ Tong htto:/www.linkedin.comvin/deantong Contributing Writer to newswithviews.com. and groundreport.com mer Dean Tong is not an attorney. He is not licensed to give legal advice and nothing herein should be construed to be legal advice. If you need legal assistance please consult with an attorney in your area by checking here http://www abanet.org/lawyerlocator/searchlawyer. him}. This e-mail is strictly confidential pursuant to the Attorney/Work-Product Doctrine. Monday, February 24, 2014 AOL: DeanTong02/24/2014 93:34 8136574930 DEAN TONG PAGE 04 Dean Tong, MSc. VITA Personal: {604 Brentwood Place Brandon, Florida 33511 813.657.4930, Ph/Fax 813.417.5362, Cell DeanTong@aol.com, E-Mail ‘www abuseaexcuse,com, Wed Site hupi//en.wikipedia.org/wiki/Dean_Tong Education: Master of Science (MSc.) Degree in Psychology and the Law in Child Forensic Studies from the Universities of Porismouth/Leeds in the United Kingdom in England under the direction of Professor Ray Bull, Ph.D (2006). Masters Thesis emiitled the Penile Plethysmograph, Abel Assessment for Sexual Interest, and MSL: Are They Speaking the Same Language? This thesis has been redacted and is now a published peer-reviewed scientific journal article under the same Title in Tevlor and Francis’ May — June 2007 issue of The American Journal of Family Therapy. Bachelor of Science in Biology and Pre-Medicine with minor in psychology from Northeastern University in Boston, Massachusetts USA (1979); Dean’s List. October 2004: Attended a two-day workshop given by David Martindale, Ph.D. entitled: “Conducting Child Custody Evaluations ~ Legal, Ethical, and Clinical Issues.” Completed 12.0 hours of training at the University of South Florida in Tampa, Florida October 2004; Attended an all day workshop given by Kathryn Kuehnle, Ph.D. entitled: "Complex Child Custody Evaluations Involving Allegations of Incest land Abuse.” Completed 6.0 hours of training at the University of South Florida in Tampa, Florida September 2001: Attended an all day DCF Dependency Court Improvement02/24/2014 03:34 8196574930 DEAN TONG PAGE 05 ‘Summit in Orlando, Florida February 2000: Attended an all day workshop given by Stephen Ceci, Ph.D. entitled ~ “Preserving the Reliability of Children’s Testimonies.” 7.0 CEU's at the University of South Florida in Tampa, Florida, From 1993 - 2008, have attended and presented scores of workshops and plenary sessions dealing with divorce, child custody, BPD (Borderline Personality Disorder), PAS (Parental Alienation Syndrome), SATD (Sexual Allegations In Divorce) Syndrome. and children’s suggestiblities/memories in Massachusetts, New York, Illinois, Pennsylvania, Virginia, Maryland, Florida, California, Colorado. District of Columbia, Washington, and Canada. Presented at the CRC (Children’s Rights Council) in 1993, 1994, 1996, 1999, 2001, and 2002. Qualifications and Experience: Dean Tong is an internationally noted author, forensic consultant, and expert witness, concentrating in the areas of divorce. child custody, abuse accusations, albeit, sexual or physical child abuse, domestic violence, etal, Parental Alienation, and Sexual Allegations In Divorce (SAID). Mr. Tong qualifies as an expert in cognitive child developmental psychology and best practice forensic child interview methods, as well as critiquing investigations by CPS and the Police. He has tendered and testified as an expert witness in civil cases from W. Virginia, Tennessee, Kentucky, North Carolina, Rhode Island and California. He has tendered and testified in criminal cases from Georgia, Alabama, Florida well as proffered testimony in a Florida criminal court, also. He was court appointed as the defense expert in an alleged criminal child sex case in Arizona in December 2006. He was retained as an expert by a law firm in Surrey, British Columbia, Canada in a case of alleged repressed memory which was tried in February 2007. Courts have allowed Tong to testify in the areas of cognitive child developmental psychology, and best practice methodology of forensic child interviews of children allegedly abused on DVD, Video, Audio, or transcript; signs and symptoms of truly abused versus non-abused children, source monitoring or proper versus improper CPS! Police child abuse investigations, SAID. Parental Alienation, Malingering or Munchausen By Proxy or Factitious Disorder, Sexual deviancy/interest testing and profiling, de facto/de novo Sexual Abuse Treatment Program (SATP) counseling, and critique of ld custody evaluations and reporss. He has consulted on protracted divorce, custody and abuse-related cases since 1995 and has been involved in the field of child sexual abuse accusations since 1984, Tong has been retained as atrial consultant or expert in court cases from all $0 states by parents and/or attorneys, and has worked with the Florida Legislature impacting the passage of 3 laws - the Spanking Bill; the Malicious False Abuse Law (F.S, Ch. 39) and the repeal of the Florida Child Abuse Registry. Dean2/24/2014 08:34 5136574938 DEAN TONG Pace 06 Tong. in addition to his work involving legal cases in civil, juvenile, criminal, and appeals courts is a former licensed laboratory medical technologist in the state of Florida (TN 19505). He was licensed to conduct blood and bodily fluid analyses and did so actively between 1978 — 2001 in hospital and reference laboratories in Massachusetts, Florida and Georgia. Mr. Tong ran his own radio talk show called Nothing But The Truth via WTMY AM-1280 out of Sarasota, Florida from 2004-2005 Of sigoificance to protective parents and mothers who have lost child custody ‘or may lose child custody in the future duc to alleged false allegations of abuse, parental alienation, or Muchausen Syndrome by Proxy (Factitious Disorder by Proxy) ‘or Malingering, Mr. Tong has been retained to assist like mothers and their attorneys in several of these cases, nationally. Please visit www.DrPhil.com and type Dean Tong in the search box, Publications: Dean Tong's third book Elusive Innocence: Survival Guide for the Falsely Accused received recognition in a professional journal article - The American Journal of Family Therapy May/June issue 2006 published by Francis & Taylor Group (Routledge) - In addition, Tong's work and web site was referenced and quoted in the recently published 2006 anthology “Child Abuse” in Gale and ‘Thomson’s Current Controversies Series. Dean Tong and his critically acclaimed work Elusive Innocence have received mention by Dr. Gordon Finley, Professor of Psychology at Florida International University in Miami, in the following article within the following Treatise: Finley, G.E. (2003). Father ~ Child Relationships Following Divorce. In J.R. Miller, R.M. Lemer, L.B. Schiamberg, & P.M, Anderson (Eds). Encyclopedia of Human Ecology, Volume 1: A -H. Santa Barbara: ABC- CLIO, pp. 291 - 293. Dean Tong and his book Elusive Innocence have been referenced by William Eddy, Esq., LCSW in his 2003 published book “Splitting: Protecting Yourself While Divorcing a Borderline or Narcissist.” Atorney Eddy says of Elusive Innocence on page 131 in Splitting “This is an excellent book for those who have been falsely accused of child sexual abuse in divorce, with many case examples and numerous resources.” Dean Tong is the author of 3 books: Elusive Innocence: Survival Guide For The Falsely Accused (Huntington House, 2002); ASHES to ASHES... Families to Dust (FumRights Press, 1997); and Don’t Blame ME, Daddy Senepiee Roads, 1992). in addition, Mr. Tong is a Contributor to the Booklet ove & Loathing: Protecting Your Mental Health & Leyal Rights When Your elec ean ie ee ete Cause. re 2000), author wograph ~ 1en Divorcing a BPD. id Creat : a ' Penile Plethysmograph, Abel Assessm They Speaking the Same Lantuane efor Sexual Interest and MSI-Il: Are published bv Tavlor and Francis in thee2/2a/2m14 03:34 8136574930 DEAN TONG PAGE 07 May ~ June 2007 issue of The American Journal of Family Therapy. On January 13, 2009 Tong’s study and article was cited and quoted by the ~ Circuit Court of Appeals for Western Wisconsin in the case of The United States of America v. Bruce J, Rhodes (Case No, 07-3953) referencing the Penile Plethysmograph. The exact scientific citation for Tong's article is ‘The American Journal of Family Therapy, 35:187-202, 2007 Copyright Taylor & Francis Group, LLC ISSN: 0192-6187 print / 1521-0383 online DOI: 10.1080/019261 80701226762 Dean Tong i also an online Op-Ed Columnist at www.newswithviews.com and www yroundreport.com. Mr. Tong authored an important article published in the 2008 Summer Issue of the international magazine In Search Of Fatherhood. Titled Fatherhood Crisis: A Time of Nightmare, Daylight and Redemption, Tong takes a hard look ‘at both the problems facing fatherhood and possible solutions to fix the same ‘over the past 40 years. And, Tong wrote the Foreword to the book I'm Going to be a Dad: Now What? (Atlantic Publishing Group, 2009). Organizations: Child Maltreatment and Family Law Section of the APA (Division 37) American Psychology and Law Society of the APA (Division 41) ‘American College of Forensic Examiners (ACFEN) - Forensic Trial Consultant ‘Thomson Reuters Expert Witness Services (TREWS) - A Division ofthe Westlaw Round Table Group ‘Academy of Behavior Profiling: Affiliate Member of Forensic Section Metropolitan Registries Children’s Rights Council ~ Washingron, D.C. International Speakers Network ~ Lifetime Member Print: Washington Post, AP, Reuters, Gannett, Scripps Howard, LA Times, Washington ‘Times, Miami Herald, Arizona Republic, Boston Globe, Tampa Tribune, Florida Times-Union, Denver Post, Christian Science Monitor, Ft, Lauderdale Sun Sentinel, Richmond Times-Dispatch, South Florida Parenting Magazine, Wilkes Barre Times Leader, The Women's Quarterly, The New American, The Florida Bar Joural, Speak Out For Children, Washington Pos, Skepical Inquirer Magazine, Ft, Myers Newspress, salon.com, Naples Daily Nows, Orlando Sentne,ifeminsts com, The Stockton Record, Nursing Spectrum, ase en Saran Herald-Tribure, Fostering Families Today, The Matatne, Op-Ed Columnists newswires ie ee Globe02/24/2014 08:34 8136574930 DEAN TONG PAGE 08 Rolling Stone Magazine, Wall Street Journal 1: Inside Edition, Count TV (Johnny Cochran Tonight), Jerry Springer Show, ‘A Closer Look w/Faith Daniels, Jane Whitney Show, CNBC, Your Turn w/ Kathy Fountain, CNN (Talkback Live), CBS Evening News w/Dan Rather, Montel Williams Show, Talk or Walk, Chicago Counterpoint w/Attorney Jeffery Leving, Florida News Channel's - The Vasilinda Report, Crier Live, ‘ABC Prime Time Thursday w/Diane Sawyer and Charles Gibson, MSNBC Live, Dr. Phil, FOX News Live, Court-TV (Crier Live), Court-TV (Both Sides w/Vinny Politan), A Current Affair, FOX News Channel ~ The Big Story and ‘The Lineup, CNN (Nancy Grace), MSNBC (Rita Cosby), CBS’ 48 Hours, Dateline NBC, Channel 9 Orlando, FL, Discovery Channel - TLC Radio: Talk America (Judi World), Morton Downey Jr. via WWRC, Sun Radio Network, Liberty Works Radio, American Freedom Network, KOA, WLW, Woal, WBZ, KABC, KGO, WMEX, Florida News Nerwork, Radio America Network, Focus on the Family w/Dr. James Dobson, WMAL, Nolan at Night, Roger Fredinburg Show, Tony Trupiano Show (Talk America), Stan Salomon ‘Show, ESPN Radio (Chicago), Steel on Steel, American Freedom Network, sconsin Public Radio, KRLA-AM 870 wiGlenn Sacks (hisside.com), Familiesundersiege.com, Behind the Ileadlines w/lane Silk, KPSI-AM Palm Springs, CA. The Ken Hamblin Show, KTSA-AM (The Morning Edge w/Trey Ware, Fox Sports Radio, The Mitch Albom Show (WIR), KTAR, Battleline w/Alan Nathan (radioamerica.org), The Bob Dornan Show, CRN, American Breakfast w/Stan Major (nationalradionetwork.com), World Talk Radio w/Annie Armen, Voice Of America w/Barbara Klein, His Side w/Glenn Sacks (www.hisside.com) (Point ~ Counterpoint Debate w/Celebrity Attomey Gloria Allred une 27, 2004), WOR w/Ed Walsh, Good Day USA (The Doug, Stephan Show), KHOW, WHO, WBT, KLIF, KLBJ, KFI, KPAM, KCMO, FOX News Radio Legal Analyst in the Jon Benet Ramsay arrest case of John Mark Carr, the resignation of former U.S. House Rep. Mark Foley, and the Duke University Rape Scandal, The Scott Paulsen Show (The Zone), Across the Nation w/Attorney Bob Dunning on Sirius Channel 159, Bulldog and the Rude ‘Awakening on Ocean 98, KFBK. KXYL 97 FM Wendiee Broadcasting (Central Texas), The I.ars larson Show - CBS Radio Awards & Significant Events: Expert Commentator for Casey Anthony Case (Orlando Sentinel ~ Anthony Collarossi, Reporter) 2011 FOX News Radio Legal Analyst Media/Trial Consultant for Bridget Marks’ Case02/24/2014 88:34 8136574930 DEAN TONG Pace 03 Media Commentator for Cour-TV in Michael Jackson Case 2005 National Wall of Tolerance sponsored by Rosa Parks Legal and Media Consultant for Elian Gonzalez Case Media Commentator for other following high-profile cases: Duke University Rape Scandal, Congressman Mark Foley Scandal. Kobe Bryant, Catholic Church Sex Abuse Scandal, Paula Poundstone, Megan's Law, Michael Jackson, Woody Allen; Who's Who in Medicine & Healthcare Dept. of Health & Rehabilitative Services ~ Florida ‘American Coalition for Fathers & Children ‘Mayor Ed Austin - Jacksonville, Florida ‘Northwest Child Abuse Defense Resource Center Candidate for Florida State House in 1994 Testified in precedent setting ‘prospective abuse” ease in 1992 in Clay County, Florida ~ In The Interest of $.S.J. References: ‘Will be fursished upon request by e-mailing Dsanong@aol.com or vist Intp:/abuse-excuse.com/testimonials! Updated November 2013