[WSBARP] Looking for creative solution to BLA

[Carmen Rowe]

I wonder ...

As this would be a quick and dirty presentation to the court, assuming that
could happen fast enough for your client, I wonder if you could do it as
enforcement of a contract?

It would be an oddity as no one is actually failing to perform. So it may
run afoul of being a legitimate "issue in controversy".

But if the court is willing to overlook that (and not raise that issue if
none of the parties do), and enter an order that requires execution of the
BLA ... ?

I think you be candid with the court why this is all necessary, so they
understand and don't wonder about something fishy. But if the parties are
all stipulating to an order to "resolve" the case, maybe a judge would be
willing to go along with it and keep on moving.


Carmen Rowe



Phone: (360) 669-3576 (direct cell)
Email:  Carmen at GryphonLawGroup.com

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Date: Wed, 24 Sep 2025 19:29:23 +0000
From: Craig Gourley <craig at glgmail.com>
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: [WSBARP] Looking for creative solution to BLA
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Listmates.    Client has a large property that he wants to give neighbors a
Boundary Line Adjustment.  Everyone is in agreement, except the County.   A
County road separates the client's property from the neighbors.   County
says the property must be "adjoining " to qualify for a BLA and the road
prevents them from being adjoining.   Rather odd since the County grants
lot status on plats with ? the lot on either side of the dedicated road.
 County says that they can't approve the BLA but can recognize a court
order if we have one.   The parties are all happy to enter and agreed
order.   My problem is that I can't think of any cause of action under
which to bring an action.  There is no controversy, no legal right to
property to decide, we are just trying to end run irrational language in a
county code.     Anyone have a creative cause of action that I can
ethically place before a judge for an agreed order?

GOURLEY LAW GROUP
THE EXCHANGE CONNECTION
SNOHOMISH ESCROW
P.O. Box 1091
Snohomish, WA 98291
PH:  (360) 568-5065 (800) 291-8401
Fax: (360) 568-8092

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