It continues to be the case as of the date of this brief that the tax map located in the
Clerk's Office of the Circuit Court of the City of Charlottesville continues to show the
entire Parent Parcel as designated as tax map-parcel number 56-40.4 (see Exhibit C).
In December of 2006, in response to the Plaintiffs and others' requests for
confirmation of the zoning of the Parent Parcel, several City officials confirmed that the
entire property at question in this case was zoned an IPP. Specifically, on January 2,
2007, in a meeting with the Plaintiff and another Woolen Mills resident, Director of
Planning James E. Tolbert confirmed that the IPP zoning covered the entire Parent Parcel.
Emails sent by the City's Historic Preservation Planner to Woolen Mills residents also
confirmed that the entire Parent Parcel was IPP-zoned (see Exhibit D). Emails sent by
the City's Historic Preservation Planner and the primary officer and member of the
Landowner Defendants also confirmed the same (see Exhibits E and F).
Upon information and belief, including documents returned by the City as part of a
Freedom of Information Act request, a meeting in January 2007 occurred between legal
counsel for the Landowner Defendants, the City attorney and other City officials.
Following this meeting, the City officials appeared to have changed their minds about the
IPP zoning of the property and thereafter maintained that the zoning on the property had
been removed on a the majority of the Parent Parcel.
Also following this meeting and, most notably, prior to any official determination
by the City's Zoning Administrator, the tax maps were apparently modified by City staff