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Perkins <br /> Cole <br /> I_0i Third Avenue,Suite 4800 <br /> Patrick W.Ryan Seattle,WA g81o1-3o99 <br /> PHONE 206.583.8662 PHONE.206.583.8888 <br /> FAX zo6.583.8500 <br /> www.perkinscoie.com <br /> October 15, 2002 <br /> VIA CERTIFIED MAIL <br /> Mr. Fredric Schroeder <br /> 1819 10th Street <br /> Anacortes, WA 98221-1417 <br /> Re: (1701 11th Street <br /> Dear Mr. Schroeder: <br /> I am writing in response to your document dated September 7, 1994. (See Attached) <br /> The document purports to be a letter demanding that my clients remove a wood fence <br /> separating the two properties, but allowing a cyclone fence in the rear of my clients' <br /> property to remain on a "permissive basis." Your intent in forwarding this document <br /> to my clients now for the first time is patently obvious. This document, however, <br /> lacks any evidentiary credibility. It is unsigned; it is addressed to "Ryan Williams" <br /> rather than my client, William Ryan; and, unsurprisingly, it was unaccompanied by <br /> any evidence that it was actually sent. In fact, my clients never received the letter, <br /> and will testify as such under oath. <br /> Even if the "letter" were a bona fide document, however, that would not affect the <br /> illegality of your actions in destroying my clients' property and trespassing on their <br /> land. <br /> As I explained to you in my letter of October 8, 2002, my clients have acquired <br /> through adverse possession superior title to the land, up to and including the wood <br /> fence you destroyed. In Washington, adverse possession is established through open <br /> and notorious, actual, uninterrupted, exclusive, and hostile possession of property for <br /> more than 10 years. See Chaplin v. Sanders, 100 Wn.2d 853, 857 (1979). Adverse <br /> possession was clearly satisfied when my clients used the property for over thirteen <br /> years of uninterrupted, continuous mowing, planting, improvements, and other normal <br /> use up to the fenced line. See id. <br /> • <br /> [40I64-0001/SL022870.305] <br /> S NCHORAGE BEIJING BELLE„UE BOISE CNIC.AGO DENVE:' NODS 'KONG LOS ANGELES <br /> MENLO PARK OLYMP:o PORTLAND CAN EPAPISISC D L'pn, ; SPni +nip , a HINGTON D C <br /> Perkins Coie LLP(Perkins Cole Lx in Illinois) <br />