New York Real Property Actions and Proceedings Code § 521

Adverse possession not under written instrument or judgment
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§ 521. Adverse possession not under written instrument or judgment.\nWhere there has been an actual continued occupation of premises under a\nclaim of right, exclusive of any other right, but not founded upon a\nwritten instrument or a judgment or decree, the premises so actually\noccupied, and no others, are deemed to have been held adversely.\n

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