BOSTON--She calls it "a case of hubris over veritas."

Kathryn J. Brookins, a resident of the Mission Hill neighborhood, refiled a lawsuit against Harvard last month, claiming the University submitted false construction plans to government agencies in order to win approval for a $60 million research facility and parking garage for the Medical School.

Brookins charges in her suit that Harvard misled community groups and the Zoning Board of Appeal (ZBA) since the University first presented the plans for the now-completed garage in 1989.

The University showed the ZBA and the Mission Hill Neighborhood Association a plan for a garage underneath the research facility, but the garage that was ultimately built was located 200 feet away from the rest of the development, Brookins says.

Brookins says that Harvard submitted plans they never intended to use in order to avoid having to apply for a second permit from the ZBA--a permit they may not have been able to obtain.

"It's like the Mafia," she says. "They keep two sets of books. One for the auditors, and one for themselves."

If Brookins wins the suit, Harvard would lose a $9 million collateral bond the University promised to forfeit if it broke zoning codes and it would be forced to demolish the recently completed structure.

Harvard claims they submitted plans calling for a separate garage located in an adjoining quadrangle throughout the approval process. According to Kevin A. McCluskey, director of community relations, Harvard sent out plans--which called for the separate garage--to about 20 public agencies in September 1989.

But at a meeting of the Zoning Board of Appeal on May 22, 1990, Harvard handed out fact sheets showing plans for a garage located under the building, Brookins said.

Brookins has stamped plans from the Boston Redevelopment Authority which include the fact sheet. The plans for the separate garage are not included.

McCluskey says that the fact sheet may be an earlier plan of the project that was accidentally inserted in the documentation.

"We never submitted a fact sheet," McCluskey says. "Everything was shown. We were clear...The only possibility is that in the reams of paper produced around any project this size, some early document was still around."

Kathy A. Spiegelman, Harvard's director of planning, told the Boston Globe that any confusion was not intentional.

"Projects are likely to change, often resulting in apparent inconsistencies which are not deliberate," Spiegelman told the Globe.

But Brookins says the fact sheet was not an accidental insertion. "If that's true," she says, "then why were they handing them out at the ZBA meeting?"