The department of education shall promulgate regulations for adjudicatory proceedings to
resolve any and all disputes arising under this section.
82. The Town of Lexington has begun a program intended primarily to indoctrinate very
young elementary school children in the notion that homosexuality and homosexual
relationships and marriage are right and moral.
83. Pursuant to Mass. Gen. Laws ch. 71 § 32A, the plaintiffs have the right to be notified and
to excuse their children from this curriculum.
84. The defendants have breached this right and by said breach have caused the plaintiffs
great damage.
COUNT IV:
CONSPIRACY IN VIOLATION OF 42 U.S.C. 8 1983
85. The plaintiffs repeat and reassert the allegations contained in the above paragraphs and
incorporate them by reference as if fully and completely set forth herein.
86. By having engaged in the conduct described above, the defendants conspired to deprive
the plaintiffs of their due process rights and their rights to equal protection of the law or
of the equal privileges and immunities under the law, and they acted in furtherance of the
conspiracy which resulted in the injury to the plaintiffs as described above, all in violation
of 42 U.S.C. 5 1983.
WHEREFORE, plaintiffs, jointly and severally, respectfully request this honorable court :
1. Pursuant to 28 U.S.C. 5 2201, to declare and rule that there exists a justiciable
controversy between the plaintiffs and the defendants;
2. Pursuant to 28 U.S.C. 5 2201, to issue a declaratory judgment declaring that each