In order to fabricate the needed record, Benveniste perjured herself, and here is how:

The Planning Board of Holland had to show a record of a vote on my ANR plan in order to win the case. Debra Benveniste first testified under oath, that the Planning Board took a vote on July 2, 2002. When confronted with her writen decision dated June 24, 2002 denying my ANR application and questioned how she was able to write the decision 8 days before the alleged vote, she said, "A good question." See Debra Benveniste's deposition part I and deposition part II. The relevant part to the perjured answer is on page 6-10 on part II of her deposition. See also corresponding COUNT LII, and COUNT LVIX of the amended complaint.