Massachusetts and regularly does business within said Town.
19. The defendant Town of Lexington, County of Middlesex, Massachusetts is a municipal
corporation that can sue and be sued.
FACTS COMMON TO ALL COUNTS
THE PARKERS
20. At all pertinent times, David and Tonia Parker, the adult plaintiffs, were married to one
another. The adult plaintiffs are the natural parents of the plaintiffs _____ and _____,
who were born on March 27, 1999, and October 30,2000, respectively.
21. In or around 2004, the adult plaintiffs, together with their two natural children, moved to
Lexington, Massachusetts following a corporate restructuring by Mr. Parker's employer.
22. The adult plaintiffs were attracted to the Town primarily by its highly-touted school
system.
23. The plaintiffs are devout Judeo-Christians. Included in their core Judeo-Christian beliefs
is the concept that issues pertaining to sexual intimacy, procreation, human sexuality, and
the holy basis of matrimony should remain private within families, be introduced by
parents, and governed by the laws of the God of Abraham. Also included is the concept
that homosexual behavior is immoral in that it violates God's law.
24. The Parkers enrolled _____ in the public schools upon reaching kindergarten age. In
September 2004, five-year old _____ began attending kindergarten classes at Estabrook
Elementary School.
25. Almost immediately thereafter, the defendants commenced an intentional campaign to
teach the Parkers' very young child that the family's religious faith was incorrect.