City Council purportedly re-zoned the property. The tax maps in effect in 2003, when
				City Council enacted the 2003 Ordinance, is clearly a probative factor in determining
				whether the 2003 Ordinance re-zoned the Daughter Parcels. Further evidence are the
				City's own maps of IPP-zoned property which continue,  to date,  to show the entire
				Property as IPP.  Finally, the near-uniformity of the language wherein City Council
				originally zoned the Parent Parcel in 1993 and that language used in the 2003 Ordinance
				suggests that City Council did not in fact intend to change the zoning on the Parent Parcel
				or Daughter Parcels. There is virtually no evidence that Plaintiff is aware of that City
				Council either intended to, or actually did, remove the IPP-zoning from the Property
				when enacting the 2003 Ordinance.
				
				
				A. Defendants' Pleas in Bar
				
				
				By Plaintiff's reading of the Defendants' briefs, the single dispositive issue in this
				case is the issue of whether the 30-day statute of limitations prohibits this Court from
				determining whether City Council re-zoned the Daughter Parcels in 2003. Clearly it does
				not.
				
				The Defendants' pleas in bar rest on the incorrect supposition that the Plaintiff's sole
				claim is that the 2003 Ordinance, as it pertains to the purported re-zoning of the Daughter
				Parcels, was void ab initio because of the failure of the City to give the notice required by
				Virginia Code sections 15.2-2204 and 15.2-2285. As is indicated above, the Plaintiff's
				argument is two-fold, namely, that when enacting the 2003 Ordinance, the City did not