representative. The meeting's subject was titled "How and Why to Talk to Your Children
about Diversity." In fact, the meeting focused exclusively upon homosexuality and how
to acclimate young children to it. Mr. Pfeifer encouraged the Committee to place many
homosexual family books in each classroom, hang gay and lesbian family posters in each
classroom, and encourage teacher-initiated discussions in each class. Mr. Pfeifer's
response to one parent's comment that kids learn negative jargon at a young age was
"kids learn easier . . . go through year after year and it'll be better." Several teachers and
the Principal of the Estabrook Elementary School attended the meeting, and visibly and
verbally affirmed this action plan.
33. On information and belief, the Town, School Committee, Ms. Jay, Mr. Hurley, and Dr.
Ash have adopted Mr. Pfeifer's suggestions. On information and belief, the purpose of
adopting these suggestions is the specific intention to indoctrinate young children into the
concept that homosexuality and marriage between same-sex partners is moral and
accepted, and that those who hold a faith such as the Parkers are incorrect in their beliefs.
Essentially, the defendants are requiring the minor plaintiffs to affirm a belief inconsistent
with and prohibited by their religion. Such indoctrination is inconsistent with the
Parkers' sincere and deeply-held religious faith.
34. As a result of these concerns, the Parkers decided to make a specific request of the
Lexington Public Schools. On March 4,2005, they wrote to the defendant Principal Jay,
the defendant Mr. Ravenelle, the defendant Ms. Wolfium, and the defendant
Superintendent Hurley. The Parkers specifically requested that no teacher or adult expose
their child to any materials or discussions featuring sexual orientation, same-sex unions,
or homosexuality without notification to the Parkers and the right to "opt out."