INTRODUCTION
This is a claim brought by four parents and their very young children against the Town of
Lexington, its school board, various administrators and a teacher. The plaintiffs are devout
Judeo-Christians. They claim that the defendants have intentionally interfered with their
Fourteenth Amendment due process rights to direct the moral upbringing of their own children.
The defendants have begun a campaign of intentionally indoctrinating very young
children to affirm the notion that homosexuality is right and moral, in direct denigration of the
plaintiffs' deeply-held faith. The plaintiffs tolerate and respect all people but wish to teach their
faith to their children at their own pace, and in their own way.
The claim is brought pursuant to 42 U.S.C. 5 1983, the Massachusetts Civil Rights Act,
Mass. Gen. Laws ch. 12, 5 1 1 I, and the Massachusetts Opt Out Statute.
PARTIES
1. The plaintiff David Parker is an individual who lives at --- ------- ------, Town of
Lexington, County of Middlesex, Commonwealth of Massachusetts.
2. The plaintiff Tonia Parker is an individual who lives at --- ------- ------, Town of
Lexington, County of Middlesex, Commonwealth of Massachusetts. Hereinafter, the
plaintiffs David Parker and Tonia Parker will be referred to from time to time collectively
as the "adult plaintiffs."
3. The plaintiff _____ Parker is an individual who lives at --- ------- ------, Town of
Lexington, County of Middlesex, Commonwealth of Massachusetts. _____ Parker is a
minor child. His parents and legal guardians are the plaintiffs Tonia and David Parker.
4. The plaintiff _____ Parker is an individual who lives at --- ------- ------, Town of