that the Commonwealth of Massachusetts endorses as legal some marriages they believe
to be inconsistent with their faith. However, they did not wish to discuss the topic of
homosexual marriage or homosexuality and transgenderism with _____ or _____ at their
current ages.
30. On information and belief, the individual defendants Joni Jay and William Hurley, as
well as the defendant School Committee members, were among those individually
responsible for introducing the book Who's in a Family to _____'s class, and they did so
on behalf of the Town. When they and the Town included Who's in a Family in the book
bag, they acted with the specific intention to indoctrinate young children into the concept
that homosexuality and homosexual relationships or marriage are moral and acceptable
behavior.
31. In order to determine whether their child would receive additional information in school
related to homosexuality and transgenderism, the Parkers initiated a dialogue via email
with the Principal of the School, Joni Jay, and the Superintendent of Schools, William
Hurley. On January 21, 2005, David and Tonia Parker met with Principal Jay to discuss
their concern. At this meeting, the Parkers repeatedly objected to any exposure to or
discussions of homosexuality, transgenderism, bisexuality, sexual orientation, and
homosexual marriage by any adult within the School to their five-year-old son. Ms. Jay
responded, "Any adult within the school can discuss homosexual families and
homosexual issues with your child. This is not a parental notification issue."
32. On or around February 8,2005, the Parkers began attending the Estabrook Elementary
School's Anti-Bias Committee meetings. On February 8,2005, the couple attended a
meeting featuring Jon Pfeifer, a Gay Lesbian Straight Education Network (GLSEN)