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captioned paragraphs and incorporate them by reference as if fully and completely set
forth herein.
78. By engaging in the conduct described above, including threats, intimidation and coercion,
the defendants interfered with and deprived the plaintiffs of their exercise and enjoyment
of their civil rights secured under the constitution and laws of the Commonwealth of
Massachusetts, in violation of Massachusetts General Laws Chapter 12, 5 111.
79. As a direct and proximate result of the defendants' violations of Mass. Gen. Laws ch. 12,
§ 11I, the plaintiffs suffered the injuries described above.
COUNT III:
MASSACHUSETTS "OPT OUT" STATUTE
80. The plaintiffs repeat and reallege each and every allegation set forth in the above
captioned paragraphs and incorporate them by reference as if fully and completely set
forth herein.
81. Massachusetts General Laws Chapter 7 1, 32A reads as follows:

§ 32A. Parental Notification of Human Sexual Education Curriculum.
Every city, town, regional school district or vocational school district implementing or
maintaining curriculum which primarily involves human sexual education or human
sexuality issues shall adopt a policy ensuring parentallguardian notification. Such policy
shall afford parents or guardians the flexibility to exempt their children from any portion
of said curriculum through written notification to the school principal. No child so
exempted shall be penalized by reason of such exemption.

Said policy shall be in writing, formally adopted by the school committee as a school
district policy and distributed by September first, nineteen hundred and ninety-seven, and
each year thereafter to each principal in the district. A copy of each school district's
policy must be sent to the department of education after adoption.

To the extent practicable, program instruction materials for said curricula shall be made
reasonably accessible to parents, guardians, educators, school administrators, and others
for inspection and review.