70. The plaintiffs repeat and reallege each and every allegation set forth in the abovecaptioned
paragraphs and incorporate them by reference as if fully and completely set
forth herein.
71. The aforesaid acts of the defendants intruded upon and impaired the adult plaintiffs'
clearly established substantive due process rights under the Fifth and Fourteenth
Amendments, as parents and guardians to direct the moral upbringing of their children,
and the clearly established rights of the minor children to such upbringing.
72. The aforesaid actions of the defendants constituted an unreasonable intrusion into the
familial privacy rights of the respective plaintiffs in violation of the plaintiffs' clearly
established rights under the Fourth and Fourteenth Amendments, and otherwise invaded
and impaired the plaintiffs' clearly established rights to privacy under the Fourth, Fifth,
and Fourteenth Amendments.
73. The aforesaid actions of the defendants invaded and impaired the plaintiffs' clearly
established rights to the free exercise of their religion.
74. The combined effect of these deprivations is synergistic and requires the state to set forth
a compelling state interest in its conduct. There is no compelling state interest in
persisting in the indoctrination techniques being utilized by the defendants.
75. As a direct result of said unlawful acts, the plaintiffs sustained great damages.
76. Pursuant to 42 U.S.C. tj 1988, plaintiffs are entitled to attorney's fees and expert fees in
connection with the bringing of the claims alleged in this count.
COUNT II:
MASSACHUSETTS CIVIL RIGHTS ACT
77. The plaintiffs repeat and reallege each and every allegation set forth in the above