2006 New York Code - Essentials Of Adverse Possession Under Claim Of Title Not Written.

    §  522.  Essentials  of  adverse  possession  under claim of title not
  written.  For the purpose of constituting an  adverse  possession  by  a
  person  claiming  title  not  founded  upon  a  written  instrument or a
  judgment or decree, land is deemed to have been possessed  and  occupied
  in either of the following cases, and no others:
    1. Where it has been usually cultivated or improved.
    2. Where it has been protected by a substantial inclosure.

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