[WSBARP] Filing an Adverse Possession claim. Legal description?

[David Faber]

Good afternoon, members of the WSBA Real Property, Probate, and Trust
section. 

I have been hired to fight a real property suit and my client wants to
counterclaim for adverse possession against the plaintiff. Because I have
never filed an adverse possession claim, I have a couple questions:

1. Do I need to have a legal description of the property to which my
client is claiming adverse possession in the counterclaim, or is it
sufficient to generally describe the area to be claimed and provide a
legal description at a later date/in a later filing? I was retained more
than half way through the 20 day answer period and am concerned I don't
have enough time to get a survey done for the purpose of drafting a
sufficient legal description. I don't have an existing property
description because my client is only claiming part of an existing space.
Any advice on this front would be much appreciated.

2. Does anybody on here have an answer and counterclaim for adverse
possession from which they'd let me crib?

Best,
David J. Faber
Faber Feinson PLLC
210 Polk st., ste. 4B
Port Townsend, WA 98368
(360) 379-4110
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