I. FACTUAL AND
LEGAL BACKGROUND 5
II. IS THERE ANYONE
WITH A RIGHT TO BE HEARD? 8
III. WHAT REMEDY IS
AVAILABLE WHEN CITIZENS HAVE
SPENT OVER $1.7 MILLION ON AN ART. 48 INITIATIVE
AND HAVE SCRUPULOUSLY DOTTED EVERY "I"
AND CROSSED EVERY "T"
AND YET THE LEGISLATURE AND GOVERNOR REFUSE TO OBEY
THE CONSTITUTIONAL REQUIREMENT THAT THE LEGISLATURE
VOTE ON THE AMENDMENT? 13
IV. IS IT AN UNUSUAL
REMEDY THAT THE PLAINTIFFS
SUGGEST? 16
V. DEFENDANT'S ARGUMENTS
ANSWERED SERIATIM 17
VI. IS IT TOO MUCH TO
EXPECT A FAIR VOTE IN
MASSACHUSETTS IN 2003? 28
VII. CONCLUSION 36
