UNITED STATES DISTRICT COURT
                             WESTERN DISTRICT OF KENTUCKY
                                       AT LOUISVILLE

ALICIA M. PEDREIRA, KAREN                    )
VANCE, PAUL SIMMONS, JOHANNA                 )
W.H. VAN WIJK-BOS, ELWOOD                    )
STURTEVANT, BOB CUNNINGHAM,                  )
JANE DOE, AND JAMES DOE                      ))         CIVIL ACTION NO._________________
               Plaintiffs                    ))
v.                                           )           COMPLAINT
                                             )
KENTUCKY BAPTIST HOMES FOR                   )
CHILDREN, INC., VIOLA MILLER,                )
SECRETARY, CABINET FOR                       )
FAMILIES AND CHILDREN, AND)
ROBERT STEPHENS, SECRETARY,                  )
JUSTICE CABINET                              ))
               Defendants                    )

                                          INTRODUCTION

       This lawsuit is brought on behalf of seven Kentucky taxpayers and one additional

Plaintiff who object to and have been injured by the Commonwealth of Kentucky's funding of

the Kentucky Baptist Homes for Children, Inc. (hereinafter "KBHC").  The KBHC uses

Commonwealth funds to hire employees who are required to accept and abide by the institution's

religious beliefs, and to pay for services that seek to teach youth the institution's version of

Christian values.

       Alicia Pedreira was employed by KBHC and then terminated because her committed

relationship with another woman is inconsistent with KBHC's religious beliefs.  Karen Vance is

barred from employment by KBHC for the same reason.  Jane and James Doe are the tax-paying

parents of a young man who was a resident of KBHC and was seriously damaged by KBHC's

policies.  Several other taxpayer Plaintiffs are clergy and concerned citizens who object to the

use of their tax dollars to fund the religion-based discrimination of KBHC.


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